On 9 February 2021, the Resolution of the Cabinet of Ministers (hereinafter – “CMU”) “On reducing the term of restrictions relating to the moratorium on certain types of audits” came into force. 

In its resolution, the CMU enabled tax authorities to perform certain types of tax audits of legal entities, including:

  1. Unfinished documentary and actual audits that were started before 18 March 2020 
  2. Scheduled documentary audits
  3. Unscheduled documentary audits:
  • to check how the deadlines for the receiving of goods imported and/or foreign currency earnings from export transactions are met;
  • transfer pricing audits;
  • based on the results of review of claims against actions or omissions of the controlling bodies regarding illegal accrual of taxpayers’ liabilities;
  • to check business entities of the real economic sector that carry out risky transactions according to the findings of the analytical system and are under investigation by the Verkhovna Rada Provisional Commission of Inquiry into facts of possible corrupt actions of public officials reported in the mass media.

This resolution of the Cabinet of Ministers is under active discussion in terms of its possible inconsistency with the current provisions of the Tax Code of Ukraine that prohibit most types of audits during the quarantine. We will follow the further updates related to this resolution and will inform you about any changes in the rules of tax audits. 

In the case that your company is going to be audited by the tax authorities, or should you have any questions regarding this alert, please contact Deloitte’s attorneys-at-law and tax advisors.






Dmytro Pavlenko

Director, Head of Legal Group, attorney-at-law, PhD in Law


+38 (044) 490 90 00

+38 (050) 464 81 46




Dmytro Lytvyn
Senior Manager, Tax & Legal
+38 (044) 490 90 00
+38 (050) 469 58 66




Roman Makarchuk

Senior Consultant, Tax & Legal, attorney-at-law, PhD in Law


+38 (044) 490 90 00

+38 (093) 974 70 07




Vasyl Drobot

Senior Manager, Tax & Legal, АССА


+38 (044) 490 90 00

+38 (063) 875 21 85




Mykhailo Koliadintsev

Assistant Manager, Tax & Legal, attorney-at-law


+38 (044) 490 90 00

+38 (050) 922 25 50