The decision of the supervisory authority to conduct an inspection! which is issu by order of the head of this authority;
admission to the inspection; examination of documents and/or other materials provided by the taxpayer;
Registration of inspection results
The implementation of the above stages means that the tax audit whatsapp lead has Code of Criminal taken place as a legal fact! on the basis of which the head of the tax authority can conclude that a tax offense has occurred and make an appropriate decision.
The Supreme Court has repeatedly drawn attention to such application of the rule of law in its judicial decisions (resolution of July 14! 2022 in case No. 160/6980/20! resolution of June 19! 2023 in case No.
According to paragraph 75.1 of Article 75 of the ! regulatory authorities have the Code of Criminal right to conduct office! documentary (scheduled or unscheduled; on-site or off-site) and actual inspections.
An unscheduled documentary inspection is not provided it is very important to have a defin strategy for in the work plan of the regulatory authority and is carried out in the presence of at least one of the circumstances specified in this Code {subparagraph 75.1.2 of paragraph 75.1 of Article 75 of the Code of Ukraine}.
An exhaustive list of cases in which the regulatory authority has the right to conduct an unscheduled documentary inspection is establish by paragraph 78.1 of Article 78 of the Code of Criminal Procedure of Ukraine.
A documentary on-site inspection is consider an inspection conduct
At the location of the taxpayer or the location of the property right object in respect of which such an inspection is conduct {subparagraph 75.1.2 of paragraph 75.1 of Article 75 of the Tax Code of Ukraine}.
In accordance with paragraph 78.4 of Article 78 of the Code of Criminal ao lists Procedure of Ukraine! the head of the regulatory authority makes a decision on conducting an unscheduled documentary inspection! which is formaliz by an order .
(!!!) The right to conduct an unscheduled documentary audit of a taxpayer is grant only if! prior to the start of the specified audit! he is given a copy of the order to conduct an unschedul documentary audit against receipt.