Tax Inspections of Private Enforcement Officers

The Tax Service steps up inspections of private enforcement officers: key areas of focus in 2025
In 2025, the State Tax Service of Ukraine (STS) resumed scheduled tax audits, which also affect private enforcement officers — self-employed individuals engaged in independent professional activity. The updated audit schedule has been in effect since March 28, 2025, and may be revised throughout the year.

After a long moratorium, tax authorities regained the right to audit tax periods starting from 2017. This is due to the suspension of the statute of limitations during quarantine restrictions: the 1095-day audit window began counting from March 2020. As a result, private enforcement officers must be prepared for a thorough review of their recent years’ activities.

Main areas of focus during tax audits in 2025:
• Timeliness and completeness of income declarations.
• Accuracy in tax calculation and payment (personal income tax, unified social tax).
• Proper bookkeeping of income and expenses.
• Timely submission of tax reports.
• Special focus on documented evidence of transactions, actual performance of actions, and the legitimate purpose of financial operations.

The tax authority’s main concerns include the justification of expenses, authenticity of business transactions, proper accounting of assets and liabilities, and compliance with tax policy regulations.

Takeaways for private enforcement officers:
• Monitor updates to the STS audit schedule and prepare all documents verifying income and expenses.
• Ensure transparency in business operations and strict compliance with the Tax Code.
• If tax violations are identified, financial sanctions may follow — it’s advisable to conduct a preventive internal audit and eliminate potential risks in advance.

2025 will be marked by increased scrutiny of private enforcement officers’ tax discipline. Experts recommend preparing early and responding promptly to tax authority requests.

It is advisable to consult legal professionals as soon as you receive a request from the STS, as communication is unlikely to end with just one notice.
If you’ve encountered similar situations — it’s worth discussing them in advance. Often, one timely consultation can prevent a host of problems.
WINNER LAW FIRM is one of Ukraine’s leading firms in tax, criminal, administrative, commercial law, and litigation.
Contact us: 067-755-55-13