As a general rule, a field audit may be carried out within a tax period of three calendar years. However, the Federal Tax Service of the Russian Federation (the “FTS”) believes that when submitting a revised tax declaration (the “Revision”), the period for which the Revision has been submitted is subject to a field audit.
The FTS has clarified that this exception applies if the Revision is submitted for a period exceeding the three preceding calendar years. In this case, the tax authorities may conduct a field audit for the period for which the Revision is submitted, which is permitted if the respective period was not previously subject to a field audit. The FTS has specified that the date of submission of the Revision (during, before, or after the audit) is irrelevant.
[Letter No. AS-4-2/8792 of the Federal Tax Service of the Russian Federation “On Paragraph 4, Article 89 of the Tax Code of the Russian Federation”, dated 29 May 2012]