What happened?

The Federal Tax Service published a Letter dated March 24, 2022, No. SD-4-2/3586@ (hereinafter referred to as the "Letter"). The Letter provides that: 

• Until March 3, 2025, the tax authorities will not conduct on-site (repeated on-site) audits in relation to accredited IT companies. The exception is the consent of a higher tax authority or the Federal Tax Service of Russia;
• Territorial tax authorities must complete in the standard procedure field tax audits, appointed before they received the Letter. At the same time, such audits cannot be extended or suspended.

What does this mean for business?

The letter supports the trend to reduce the tax burden on the IT-industry. Moreover, in the near future we should expect the expansion of such support measures. So, the state is very likely to increase the number of IT-companies that will be able to claim tax exemptions.

At the same time, it is important for the IT-business to remember that: 

• After the Letter is issued, ongoing desk and field audits will not stop;
  
• During the moratorium on field audits the tax authorities will be able to conduct desk audits, commissions to clarify tax liabilities and other control measures (interrogations, request of documents, etc.);
• The moratorium on field tax audits applies to previous tax periods. At the same time, in 2025 the tax authorities will be able to appoint an audit for the period from 2022 to 2024.

In view of the above, businesses should be careful in recording and documenting transactions for tax purposes.