
The State Tax Service has circulated for public consultations draft amendments and additions to the Methodological Guidelines for Tax Audits approved by STS Order No. 508/2024. They were developed in order to harmonize the STS regulations with the current legislation and to improve tax audit procedures. Amendments and additions to the regulatory framework are also undertaken in the context of digitalization of certain procedures. In accordance with the project, the Methodological Guidelines on tax audits will be partially revised.
Thus, within the framework of tax control on the basis of the application for registration as a VAT payer/authorized warehouse operator will be considered for a period not exceeding the statute of limitations set forth in Article 264 of the Tax Code. The control will be performed to determine the tax liability for the last 4 years starting from the date of registration of the taxpayer.
If the initiative is approved, the wording of paragraph 3.9 of the Methodological Guidelines will also be revised. It will state that if a taxpayer disagrees with the results of a tax audit report, the taxpayer has the right to submit its objections within 3 working days of its receipt.
The application must be accompanied by justification and attachment of necessary documents. It will be reviewed by the Tax Service Directorate with the provision of a response to the taxpayer or, as the case may be, revision of the results of the tax audit with the preparation of a new report.









