As of January 1, 2026, amendments have come into force in Russia that fundamentally expand the scope of tax control. One of the key innovations is extraterritoriality of desk tax audits. Now, your tax return may be reviewed not only by the inspectorate at your place of registration but also by any other tax authority authorized by the Federal Tax Service. This step aims to enhance control efficiency and eliminate reliance on local inspectorate ties.
However, there is a flip side: businesses face new risks, while the desk audit itself effectively turns into a "mini on-site inspection" with expanded powers for inspectors. We examine what has changed and how to protect your interests.
What Has Changed in Desk Audits Since 2026
The key trend of the 2026 tax reform is digitalization and expanded inspector powers. Previously, a desk audit was essentially a "desk-based" procedure, but now its boundaries have significantly widened:
Extraterritoriality of audits. Your tax return can now be reviewed not only by the inspectorate at your place of registration but also by any other tax authority authorized by the Federal Tax Service. This helps eliminate local corruption risks but also means that auditors may be unfamiliar with the specifics of your business.
Desk audits become "mini on-site inspections." Since 2026, tax authorities have been granted the right to conduct seizure of documents and items (e.g., computers, servers) even within the framework of additional tax control measures during a desk audit. Previously, such actions were only possible during on-site inspections.
A "second wave" of inspections. Inspectors may conduct premises and territory inspections not only during the audit itself but also during the review stage of the audit materials. This provides them with a powerful tool to gather evidence to counter your objections — allowing them to arrive at a time when you have not yet had the chance to prepare your office and production facilities.
How to Challenge the Results of a Desk Audit: A Step-by-Step Guide
If you receive an audit report with additional assessments, it is crucial to follow the procedure strictly. Any mistake in timing could cost you the right to defense.
Step 1. Receive the Tax Audit Report
Upon completion of the desk audit (typically 3 months, or 2 months for VAT), the inspector prepares a report. The date of its delivery is the starting point for your actions. The deadline for delivering the report is 5 business days from the date of its preparation. If the report is received via electronic channels (TKS), the sixth day from the date of sending is considered the date of receipt.
Step 2. Prepare and Submit Objections
You have exactly 1 month from the date of receiving the report to submit written objections (Article 100(6) of the Tax Code of the Russian Federation). In your objections, it is important to:
rebut the facts: prove the reality of transactions by attaching contracts, waybills, business correspondence;
point out procedural violations: missed deadlines, lack of notifications;
refer to case law and letters from the Ministry of Finance.
Objections can be filed remotely: via the taxpayer's personal account on the FTS website, the Gosuslugi portal (for individual entrepreneurs), via TKS, in person, or by mail via registered letter with inventory.
Step 3. Participate in the Review of Materials
You must be invited to the review of the audit materials. Since 2026, this often takes place via videoconference. Do not ignore the invitation — personal presence (even online) allows you to promptly provide explanations and resolve some claims on the spot.
Step 4. Receive the Final Decision
After reviewing the materials and possibly conducting additional measures, the inspectorate issues a final decision: to hold you liable or to drop the claims.
How to Reduce the Fine
Even if a violation occurred, you have the right to request a fine reduction. If at least one mitigating circumstance exists, the fine must be reduced by at least half (Article 114 of the Tax Code of the Russian Federation). Court practice confirms the possibility of reduction by up to four times.
What Constitutes Mitigating Circumstances:
difficult financial situation; for individual entrepreneurs – illness, dependents;
committing the violation for the first time;
lack of intent (e.g., technical error, software glitch);
admission of guilt and remediation of damage (paying additional tax) before the decision is issued;
charitable activities of the company;
social significance of the business (e.g., being a city-forming enterprise).
A petition to reduce the fine should ideally be filed together with the objections.
If You Are Unsatisfied with the Decision: Filing an Appeal
If you disagree with the inspectorate's decision, you have 1 month to file an appeal with a higher tax authority — the regional branch of the Federal Tax Service (UFNS). The appeal must be filed through the inspectorate that issued the decision (do not send it directly to the UFNS). If the deadline is missed, you can file a standard complaint within one year.
What Businesses Should Do
Under the new rules, it is essential to:
be prepared for the possibility that a desk audit may be conducted by an inspectorate other than your "home" one;
respond promptly to inquiries and notifications;
build a solid evidence base for actual business transactions;
upon receiving an audit report, do not delay in preparing objections;
exercise your right to reduce the fine by citing mitigating circumstances.
How Acsour Can Help
Acsour experts are ready to:
conduct risk analysis and prepare your company for potential audits;
assist in preparing objections to the audit report using up-to-date case law;
provide support during the review of audit materials and interactions with tax authorities;
Contact us — we will help build a robust tax protection system and minimize the risks of additional assessments.