On-site tax audits have become even more complex and unexpected for businesses. Since January 1, 2026, amendments to the Tax Code have significantly expanded the powers of tax authorities. Now inspectors can review not only the three years preceding the year of the audit decision but also any completed tax periods of the current year.
What Has Changed
Previously, a tax audit covered a maximum of three years prior to the decision to conduct it. This gave businesses some breathing room — mistakes made in the current year could be corrected without the immediate threat of an audit. As of 2026, this "protection" no longer exists. If a decision on an audit is made in, say, August, inspectors are entitled to review closed tax periods from the first months of that same year.
The new rule applies to taxes with reporting periods shorter than a year: VAT, excise duties, and gambling taxes. For annual taxes (corporate profit tax, simplified taxation system, property taxes), the previous procedure remains in effect.
In addition, tax authorities can now conduct inspections and seize documents even after the audit report has been issued. Previously, such measures could only be taken during the audit itself, but now they are also possible during the stage of additional measures. This means that even when a company believes the audit is complete, inspectors may return to request original documents or inspect premises if they deem it necessary.
Starting September 1, 2026, businesses will be able to participate in the review of audit materials remotely, and the tax authority may send notifications about summons or requirements through personal accounts or the State Services portal, moving away from paper letters.
What This Means for Your Business
In the past, companies could afford to "leave for later" the resolution of certain issues. Now this approach becomes risky. Mistakes made in the first quarter can come back to haunt you in the second half of the year — and corrections will have to be made not on your own initiative, but at the request of the tax inspectorate.
Special attention should be paid by companies that exhibit signs of a potential audit: low tax burden, losses for several consecutive years, a high proportion of VAT deductions, wages below the industry average, or counterparties with signs of shell companies.
How to Prepare
To minimize risks, it's wise to reconsider your approach to tax accounting. The main rule is to document the economic rationale for each transaction at the time it is made, rather than creating explanations retroactively.
It is essential to conduct an internal audit for taxes with monthly or quarterly reporting requirements. Ensure that all primary documents are in order and that VAT deductions are well-founded. Also, be prepared for the possibility that tax authorities may conduct inspections or seizures of documents after the audit report has been signed.
How Acsour Can Help
Acsour experts are ready to help businesses adapt to the new rules:
Conduct a tax risk audit to identify weak points before the tax authority does.
Prepare documents and explanations that will stand up to scrutiny.
Provide support at all stages of interaction with the tax inspectorate.
Want to check if your business is ready for the new rules?
Submit a request — our experts will conduct an audit and help you reduce risks.