The courts supported the tax authorities and confirmed that the period under review does not depend on when the decision was handed over or the field tax audit actually began. In particular, the Arbitration Court of the Ural District considered the following situation: on December 30, 2020, the tax authorities issued a decision on afield tax audit for 2017-2019. The taxpayer received the decision in January 2021 and challenged it, believing that the tax authorities do not have the right to conduct an audit for 2017, if the respective decision was handed over only in 2021. The court did not agree with him and supported the position of the tax authorities (Resolution of the AC of the Ural District of 03.12.2021 in case N A60-18979/2021).
NAZALI TAX & LEGAL