Many businesses already know this scene, and the rest will encounter it sooner or later: someone is standing at the door, showing an ID, and stating that they've come from the tax service. What you do in the first few minutes often determines the course of the entire process that follows: orderly and documented, or one where, later on, neither side can say exactly what happened.
One thing should be clear from the start: an inspector's appearance at the door does not in itself mean they can freely intrude into the business's operations. The Tax Code recognizes several distinct forms of control, and each has its own, fairly strict rules: who can come, when, and on what grounds.
First: Figure out which procedure you're dealing with
This is where everything starts. Current control procedures - inspection, inventory, chronometry, control purchases are usually carried out without prior notice and are aimed at a specific, narrow issue, for example, checking receipt issuance on a particular day. This is different from a field tax audit, which is more systemic in nature.
For a field audit, the law sets specific deadlines: the taxpayer must be sent written or electronic notice no less than 10 working days before the audit begins, and the audit itself must start no later than 30 days after this notice is delivered, if this deadline passes, the notice is considered void. So if the inspector tells you they're conducting a field audit but you received no prior notice, that's the first thing to clarify.
The exception is an urgent field audit, which can be carried out without prior notice, but only when specific grounds exist (for example, suspicion based on violations found in a previous audit, assets of suspicious origin, or a risk of documents being destroyed or hidden) and, importantly, with court authorization. Before receiving court authorization, the tax authority has no right at all to begin an urgent field audit, it may only seal the documents or inventory items necessary for the audit while the court is deliberating. If the court does not grant authorization, the seal must be removed.
Ask them to state exactly which procedure they are conducting and, in the case of an urgent audit, whether court authorization already exists.
Second: Request identification and grounds in written form
Showing an ID is only the first step. A taxpayer has a legal right to request information about the grounds for the tax control being carried out against them, and, in the case of a field audit, to be present at the audit in person and to receive from the tax authority the original or a certified copy of any decision related to it. This is in no way an expression of distrust: it is simply an ordinary right provided by law, and a good-faith inspector will not be hindered in any way by such a request.
Third: Don't obstruct, but don't over-cooperate either
The law provides for liability for resisting an authorized official: physically stopping the inspector or ignoring a lawful demand creates a separate risk, independent of the outcome of the audit itself. At the same time, a taxpayer has a direct legal right not to comply with an unlawful act or demand of the tax authority meaning cooperation does not mean complying with everything without thinking it through. As for documents: during a field audit, the inspector has the right to request a certified copy of accounting documentation, and if this is not provided, to seize the original (which is returned to the taxpayer immediately upon completion of the audit, with a seizure protocol drawn up). Accordingly, the reasonable standard is to hand over exactly what is specifically requested and what falls within the stated scope of the audit.
Fourth: Think before you sign, don't sign anything without analyzing it
During the very first visit, they often ask for an explanatory statement or another document to be signed on the spot. Don't rush. You have the right to read it, take time, and consult a lawyer if needed, before you sign or submit a written response.
Fifth: Record and document everything that happens
The inspector's name, position, the time of the visit, the actual circumstances, these details may seem merely formal, until the matter reaches a dispute. If it does, these very records become the main evidence of whether the procedure was followed or not, including whether the 10-day notice period was observed, or, in the case of an urgent audit, whether court authorization existed.
Sixth: Call - contact your lawyer or accountant immediately
You can calmly tell the inspector that you're waiting for a consultant or lawyer by phone - this is a common, entirely lawful practice, especially if the matter involves a complex or urgent audit.
An unexpected visit from a tax inspector is stressful, but it is a process strictly regulated by law, with specific deadlines, grounds, and, for urgent cases, even judicial oversight. Whoever keeps calm in the first few minutes, checks the type of procedure, requests documented grounds, and records everything, significantly reduces the risk that a procedural flaw will later grow into a substantive problem.
Often the biggest mistake isn't a lack of documents but losing control in the very first minutes — signing without thinking, handing over information that wasn't requested, or, conversely, showing excessive resistance. That's exactly why it's worth having a procedure in place in advance: who answers the door, who gets called first, and what can be handed to the officer before consulting a lawyer.