Callback
  • From a market stall to a store

  • -

  • From a store to a retail chain

  • -

  • From retail to manufacturing

Source Documents for Sole Proprietors and Stores: Preparation, Corrections, and Retention

17.09.2026 10:00
Andrii Toverovskyi
Andrii Toverovskyi

Expert in tax and legal business matters

To substantiate a purchase, sale, product return, or store expense, keep documents that evidence the actual transaction and record it correctly in your own accounts. First determine what happened: goods were transferred, a service was received, an advance was paid, or money was refunded. Then check which document confirms that specific action, who is responsible for preparing it, and where the original will be stored.

For a legal entity, source documents are the basis for accounting. For an individual entrepreneur (FOP, the Ukrainian abbreviation for individual entrepreneur), the required documents and accounting procedures depend on the tax system, value added tax (VAT) registration status, and whether the entrepreneur must keep records of inventory. The rules below concern business activity in Ukraine and Ukrainian law.

How to determine what a document confirms

Under Articles 1 and 9 of Ukraine’s Law No. 996-XIV, a source document contains information about a business transaction and is the basis for recording it in accounting. A business transaction is an action or event that changes an enterprise’s assets, liabilities, or equity. An accountant therefore checks both the document and the actual circumstances: what was received, transferred, used, or paid for. Signatures and stamps cannot substantiate a delivery that never took place.

For store operations, it is useful to distinguish between these documents:

  • Contract sets out the parties’ agreement: goods, price, delivery, payment, and acceptance. Signing a contract does not by itself confirm that the supplier has delivered the goods.
  • Payment invoice or pro forma invoice usually states what needs to be paid for and how much. If it describes only a future delivery, it does not confirm that the goods were actually received.
  • Payment instruction contains an instruction to transfer funds. To confirm the movement of funds, check that it was executed and review the relevant bank statement.
  • Delivery note or handover and acceptance report records the transfer of specific goods or other property.
  • Service or work completion document describes the actual result or scope of services and the period in which they were provided.
  • Fiscal receipt documents a settlement transaction. It should be linked to the relevant sale, payment, or refund.
  • Accounting register aggregates information from documents. An entry in an inventory spreadsheet does not, by itself, confirm where the goods came from.

Illustrative example. A store orders 20 lamps at UAH 300 each, for a total of UAH 6,000. The supplier receives the full prepayment but delivers only 15 lamps worth UAH 4,500. The payment documents confirm a transfer of UAH 6,000, while the delivery note should show the actual transfer of 15 units. Goods worth UAH 1,500 remain undelivered. If an employee signs a delivery note for all 20 units, the documents will conflict with the actual receipt.

Which rules apply to companies and sole proprietors

A legal entity organizes its accounting document flow

Articles 2, 8, and 9 of Law No. 996-XIV require legal entities to keep accounting records. The head of the entity ensures that transactions are documented, determines which employees may sign documents, and approves the document flow procedures. If accounting is outsourced, the process for receiving documents from sales staff, the warehouse, and counterparties needs to be agreed.

Under Sections 2.12 and 5.1 of Regulation No. 88, the head approves a list of people authorized to sign documents for the release of property and funds, and sets out a document flow schedule by order. The schedule specifies deadlines for creating or receiving documents, accepting them for accounting, sending them for processing, and transferring them to the archive. The enterprise determines its own document forms and electronic exchange procedures in line with its operations and applicable requirements. Its accounting policy should be consistent with these rules. For example, a storekeeper confirms the quantity of goods received, a manager obtains a properly prepared delivery note from the supplier, and an accountant checks it before recording the transaction.

A sole proprietor under the general tax system substantiates income, expenses, and the origin of goods

Under Paragraphs 177.2, 177.4, and 177.10 of the Tax Code of Ukraine (TCU), an entrepreneur keeps records of income and expenses and must have documents showing the origin of goods. Expenses that are not supported by documents cannot be included in business expenses. Having a document also does not mean that every purchase reduces taxable income: the expense must comply with Article 177 and be connected to the business.

A recommended set of documents for a goods purchase includes a document confirming receipt, proof of payment, and information linking the purchase to business activity. Keep personal purchases separate so an accountant does not mistakenly include them as expenses.

A sole proprietor under the simplified tax system keeps records under their tax regime

Under Paragraph 296.1 of the TCU, sole proprietors in Groups 1 and 2, and Group 3 without VAT, record income received each month in any format. Group 3 sole proprietors registered for VAT keep records of income and expenses using the prescribed standard form. Article 44 of the TCU also requires documentary substantiation of tax return figures.

It is useful for an entrepreneur to address three questions separately: how income is recorded, whether the entrepreneur must use a registrar of settlement transactions (RRO) or a software registrar of settlement transactions (PRRO), and whether inventory records are required. Exemption from one obligation does not automatically waive the others. In particular, Paragraph 296.10 of the TCU exempts Group 1 from using an RRO or PRRO, but does not remove the requirement to substantiate tax return figures.

Company accounting registers, a cash book, and the full set of internal orders should not automatically be imposed on a sole proprietor. The entrepreneur organizes documents according to their own legal obligations.

When Inventory Accounting Procedure No. 496 applies

Under Section I, Paragraph 1 of Procedure No. 496, it applies to sole proprietors required to keep inventory records under Ukraine’s Law on the Use of Registrars of Settlement Transactions in Trade, Food Service, and Services. First check whether the entrepreneur conducts settlement transactions within the meaning of that Law, since Article 3 establishes the relevant obligations for such entities. Then check the exemption in Paragraph 12 of Article 3 of Ukraine’s Law No. 265/95-VR of July 6, 1995: it exempts sole proprietors under the simplified tax system who are not registered for VAT from keeping inventory records, except entrepreneurs who sell technically complex household goods subject to warranty repair, medicinal products, medical devices, jewelry and household items made of precious metals, precious stones, precious stones of organic origin, and semi-precious stones.

The exemption does not apply to entrepreneurs selling those goods.

If the obligation applies, the entrepreneur begins using the Inventory Records Form by entering the goods already held on the date the obligation arises. This entry is based on an inventory description prepared by the entrepreneur, listing names, quantities, units of measurement, and values set by the sole proprietor; supplier and recipient details are not required for this description. If there is no inventory, no such entry is made. Subsequent receipts must be entered in the Inventory Records Form before the goods begin to be sold, and source documents must be retained as mandatory attachments. Records are also kept for each place of sale, and transfers between the entrepreneur’s own stores must be supported by internal transfer documents.

For these records, documents must include the supplier’s and recipient’s names and their tax identifiers: the taxpayer’s registration number or the code in Ukraine’s Unified State Register of Enterprises and Organizations. For people who have officially refused a tax number on religious grounds and have the relevant passport notation, the passport details specified by the Procedure must be provided. The document must also state the transaction date, product name, quantity, and value. Procedure No. 496 provides a separate exception for documents concerning the destruction or loss of goods, or their use for the entrepreneur’s own needs: these should state the value at purchase price, substantiated by accounting records, without supplier or recipient details.

Practical guidance for a seller: before putting a new shipment on display, check that there is a receipt document and that it has been entered in the Inventory Records Form. A standard inventory entry in software must be checked against Procedure No. 496. The entrepreneur also records documented disposals in the Form: internal transfers, returns to suppliers, destruction, loss, use for the entrepreneur’s own needs, and cashless sales that the law allows without an RRO or PRRO. Sales data from an RRO or PRRO are not entered in Column 8. Entries for receipts and disposals must be made in chronological order.

Which documents to prepare for store transactions

The set below is a practical guide. The final set depends on what actually happened, the contract, and any special rules for the transaction. General requirements do not impose a uniform obligation for both parties to sign every document.

TransactionWhat to prepare or obtainWho acts and what to check
Goods purchaseDelivery note or other document confirming actual receipt; payment documents; transport documents, if needed for the shipment.The supplier documents the release; the recipient checks the product names, quantities, and condition. Any discrepancies are recorded during acceptance.
Goods saleSettlement document where required by law; delivery note or other transfer document where appropriate for the sales method.The seller documents the actual goods and payment. For a shipment to the buyer’s representative, the seller checks that the representative is authorized.
Services, work, rentalA document stating the specific content, scope, and date or period of performance; the contract; proof of payment.The service provider describes what was actually done. The customer checks the result and the acceptance procedure agreed in the contract.
Customer returnA document for the goods accepted back, referring to the sale; a refund document consistent with the payment method.The seller checks the goods and quantity, records their condition, and documents the return separately from the original sale.
Return to supplierDelivery note or report confirming the actual return and referring to the purchase; documents showing the refund or credit.The responsible representatives agree on the items being returned. The accountant checks the goods movement and settlement separately.
Store expensesDocuments for materials or services received, payment, and, where needed, use or write-off.The employee submits supporting documents, the responsible person explains the purpose of the purchase, and the accountant checks its accounting and tax treatment.
Goods used for own needsAn internal document stating the name, quantity, value, date, and reason for the disposal.The owner or authorized employee documents the actual withdrawal. For a sole proprietor subject to Procedure No. 496, its specific details apply.
Free transfer, donationA document confirming the actual transfer, listing the property, quantity, value, and recipient’s identity; documents showing the basis and authority.The person transferring the property checks the recipient and records the transfer. The simplified rule allowing a customer’s signature to be omitted from service documents does not apply to these contracts.
Cash movementCash or settlement documents appropriate to the entity’s status and the type of transaction.A legal entity’s cashier uses the required forms and signatures. A sole proprietor does not keep a cash book.
Goods transportationThe transport document required for that type of shipment and a document confirming the goods transfer.The sender, carrier, and recipient document their actual actions. The accountant checks which action each document confirms.

When purchasing goods, designate an employee authorized to accept them and sign the relevant documents. Under Paragraph 2.4 of Regulation No. 88, the recipient’s authority may be confirmed, among other things, by a written contract, power of attorney, or resolution of the legal entity’s governing body. The director does not have to sign every delivery note personally if signing has been lawfully delegated to another person.

How to check mandatory details

Part 2 of Article 9 of Law No. 996-XIV sets out these general mandatory details for source documents:

  • the document or form name;
  • the preparation date;
  • the name of the enterprise on whose behalf the document was prepared;
  • the content and scope of the transaction and its unit of measurement;
  • the positions and surnames of the people responsible for the transaction and for preparing the document, subject to the statutory exception for documents whose requirements are set by the National Bank of Ukraine;
  • a handwritten signature or other information that identifies a participant in the transaction.

A number, place of preparation, identification code, and stamp are not universal mandatory details. However, special rules may require additional information. For example, documents for a sole proprietor’s inventory records are checked under Procedure No. 496, while cash orders are checked under National Bank of Ukraine Regulation No. 148. Therefore, the absence of a code on a freely prepared report and the absence of a mandatory detail on a special document are assessed under different rules.

Minor defects are not, on their own, grounds for rejecting a transaction if they do not prevent identification of a participant and the document contains the date, enterprise name, transaction content and scope, and other required information. For example, a missing optional stamp is not the same as a lack of evidence for the transaction. At the same time, the document must make clear who actually did what.

To check the substance, ask an employee to answer three questions from the document: what goods or result were received, in what quantity or scope, and when this happened. An entry such as “services under the contract” should be made more specific so the work performed and its scope can be established.

When a service document may omit the customer’s signature

As of April 1, 2026, an amendment to Part 2 of Article 9 of Law No. 996-XIV, introduced by Law No. 4791-IX of February 24, 2026, is in force. For services, work, and the hire or rental of property, omitting the positions, surnames, and signatures or other identifying details of the customer or hirer does not violate document preparation requirements if all of these conditions are met:

  1. The document states the date or period in which the services were provided, the work was performed, or the property was hired.
  2. This method of documenting the transaction is provided for in a written contract.
  3. The transaction is recorded in the accounting period in which it occurred.

This rule does not apply to transactions paid with public funds; rental of state or municipal property; construction contracts and design or survey work; or contracts for donations, charitable aid, or humanitarian aid. It also does not create a general permission to document goods transfers without appropriate evidence of receipt.

Before using this procedure, review the contract: how the service provider sends the document, how the customer reports discrepancies, and how the parties determine the actual scope. The service provider’s details and other required information must still be retained.

How to prepare an invoice, record payment, and handle a tax invoice

The label “invoice” does not determine a document’s accounting role. An invoice for a future delivery states the proposed terms. A detailed, paid invoice for a service actually provided may serve as a source document if it reflects actual performance, contains the required details, and follows the agreed lawful document procedure. Payment itself may be an advance, so it is not enough to establish that a service was provided.

Recommended procedure for the accountant: check the contract, invoice contents, service period, proof of payment and performance, and the necessary signatures or conditions for lawful documentation without the customer’s details. If the invoice describes only future work, obtain a document confirming its completion.

A tax invoice serves a separate purpose under Article 201 of the TCU. VAT payers issue it, including for supplies or prepayments, and register it in the Unified Register of Tax Invoices. Paragraph 201.10 sets out its significance for the buyer’s input tax credit. However, an invoice for an advance does not establish that the buyer has already received the goods. Keep documents confirming the actual transaction for acceptance, inventory, and accounting records.

How to align document format, language, and dates

Paragraphs 1.4, 2.6, and 2.7 of Regulation No. 88 allow the use of custom-made forms containing the required details. If a special form or additional requirements apply to a transaction, the custom form must account for them. Documents are prepared in Ukrainian, and documents in a foreign language that support accounting entries must have an accurate Ukrainian translation.

The preparation date must reflect when the document was actually prepared. If the transaction date or service period differs, state it separately. Do not change the signing date to conceal a delay. Part 5 of Article 9 of Law No. 996-XIV requires transactions to be recorded in the reporting period in which they occur, while Paragraph 3.4 of Regulation No. 88 requires information to be transferred to registers in time for reports to be prepared promptly.

These general rules do not establish one deadline such as “prepare every delivery note within three days.” Some transactions have their own rules. For example, under Paragraph 32 of Regulation No. 148, cash accepted or paid out under cash orders must be handled only on the date they are prepared. For cash sales, Paragraph 2.1 of Regulation No. 88 allows a source document to be prepared at least once a day based on cash register data and receipts.

Practical guidance for a store: send goods receipt documents to the accountant daily or on the next business day, and check all outstanding transactions before the end of the reporting period. This is an internal procedure that the enterprise sets in light of its operations.

What to do when a counterparty’s document is delayed

Under Paragraph 2.5 of Regulation No. 88, an enterprise may provide in its document flow procedures for using a properly prepared internal report if the counterparty’s document has not arrived by the time the registers for the reporting period are completed. An officer responsible for accepting or releasing goods, work, or services prepares the report.

The report must describe the actual transaction and a reasonable valuation. When the counterparty’s document arrives, the accountant compares it with the report and adjusts any difference in valuation under Paragraph 3.4 of Regulation No. 88. This procedure concerns an enterprise’s accounting records and does not replace specific requirements for substantiating an input tax credit or a sole proprietor’s inventory records.

How to retain the electronic original and verify its signature

Under Articles 5–8 of Ukraine’s Law No. 851-IV, the electronic format alone does not reduce a document’s legal force. An electronic original must contain the required details, have an appropriate electronic signature, and allow its integrity and authenticity to be verified.

A scan of a signed paper document is an electronic image of a copy. A PDF file may also be an electronic document original if it was properly created and signed. The file extension and a visible image of a signature do not determine its status.

A qualified electronic signature (QES) has the legal force of a handwritten signature under Part 6 of Article 18 of Ukraine’s Law No. 2155-VIII. The law also does not allow other electronic signatures to be rejected solely because they are not qualified. However, the acceptable type of signature must be determined for each document in light of the law and the parties’ agreement.

For example, Paragraph 23 of Regulation No. 148 requires an enterprise employee to use a QES to sign an electronic cash document. A sole proprietor may sign an electronic cash document using a qualified or advanced electronic signature. To use an advanced signature, Paragraph 23 requires a contractual basis, technology specified by the business entity, and compliance with legislation on electronic documents and electronic trust services, as well as the relevant regulatory acts of the National Bank of Ukraine. Under Article 9 of Law No. 996-XIV, automatically generated source documents are used in accounting if they have an electronic signature or seal as required by law.

  1. Obtain the complete signed set. Save the document together with signature files if they are separate.
  2. Verify integrity and the signer. Save the verification result and available information about the certificate and signing time.
  3. Check authority separately. A valid signature identifies the signer, but separate documents confirm their authority to accept goods or act on behalf of a company.
  4. Record receipt. Agree with the counterparty on how delivery is confirmed and keep receipts or other evidence.
  5. Check that the document can be restored from the archive. Open the saved document and confirm that its signature can still be verified after download.

Article 13 of Law No. 851-IV requires information to remain accessible, the document to be restorable in its original format, and available data on its origin, dispatch, and receipt to be retained. In practice, this requires a backup and a designated person who can access the archive if an employee or service changes. If an enterprise creates and stores source documents and accounting registers electronically, it must, at its own expense, produce paper copies upon request from other transaction participants and from law enforcement and other relevant authorities acting within their lawful powers. This obligation is established by Part 6 of Article 9 of Law No. 996-XIV and Paragraph 2.2 of Regulation No. 88.

How to correct an error while preserving the original data

Chapter 4 of Regulation No. 88 sets out the correction procedure. Erasures and undocumented corrections are prohibited.

For a paper document where corrections are allowed, cross out the incorrect text or number with a single line so it remains legible. Write the correct information above it, add the words “corrected,” the date, and the signatures of the people who signed the document. If several participants hold copies, it is practical to agree on the correction so their documents do not conflict.

Corrections are not allowed in documents for cash, banking, or securities transactions. Follow the applicable procedure for preparing a replacement or other document under the specific rules. In particular, Paragraph 32 of Regulation No. 148 expressly prohibits corrections to cash orders and cash disbursement statements.

Errors in electronic source documents and accounting registers are corrected through reversal entries or additional accounting entries. Under the reversal method, make a reversing entry for the amount of the error and state the correct amount at the same time. Keep the original information, state the correction date, the positions and surnames of the people who prepared the corrected electronic document, and their signatures or other data that identify them. Make corrections in the reporting period in which the error is found. This is why a signed file cannot be silently replaced with another file under the same name.

For errors in accounting registers from a prior reporting period, Paragraph 4.6 of Regulation No. 88 provides for an accounting memorandum stating the reason for the error and referring to the documents and registers. The preparer signs it, and the chief accountant signs it after review. The memorandum explains an accounting correction; it does not substantiate a purchase that never took place.

A sole proprietor who keeps an Inventory Records Form under Procedure No. 496 enters “cancelled - corrected” in the “Notes” column of the incorrect row and states the number of the corrected row. In the “Notes” column of the new row, they enter “corrected” and the number of the incorrect row. If an entry should simply be deleted without replacement, enter “cancelled” in its “Notes” column.

How long to retain source documents

The retention period depends on the taxpayer, the document’s purpose, and the circumstances in which it is used. Under Paragraph 44.3 of the TCU, these minimum periods apply:

Minimum periodDocuments covered
2,555 daysDocuments and information used for tax control under Articles 39 and 39-2 and Paragraph 141.4 of the TCU. If relevant transactions exist, keep them in a separate archive category.
1,825 daysSource documents, accounting registers, financial statements, and other specified tax documents of persons covered by Paragraph 133.1, Subparagraph 133.2.2, and Paragraph 133.4 of the TCU, as well as legal entities under the simplified tax system, unless a longer period applies.
1,095 daysOther documents not covered by the two preceding categories. As a general rule, this category includes tax documents of sole proprietors, unless a longer special period applies.
1,095 daysDocuments concerning compliance with other legislation monitored by tax authorities, including permits.

For documents used in tax returns, the period runs from the date the return is filed or, if it is not filed, from the filing deadline set by the TCU. For documents concerning other legislation subject to control, the period starts from the relevant transaction; for permits, it starts when they expire. Therefore, the date on a delivery note is not always the start of the retention period.

Retention periods are extended for any period during which the statute of limitations is suspended under the circumstances in Paragraph 102.3 of the TCU. Under Paragraph 44.4, documents related to an audit, administrative appeal, or court case must be retained until the relevant proceedings and appeal periods end, and for at least the applicable minimum period. A separate case is set out in the second paragraph of Paragraph 44.4: if a taxpayer receives information from a controlling authority under Paragraph 86.14 about circumstances involving the possible provision of an undue benefit to an official of a foreign state, the taxpayer must retain documents that substantiate those circumstances or formed the basis for accounting for related transactions for the periods in Paragraph 44.3 plus 1,095 days.

How to account for archival requirements for a company

The List approved by Order No. 578/5 of the Ministry of Justice of Ukraine sets a minimum retention period of five years, subject to the relevant notes, for source documents and attachments that substantiate transactions and support accounting and tax entries. This is separate from the 1,825-day tax period: comply with both requirements when they apply. For documents and information covered by Articles 39 and 39-2 of the TCU, the notes referred to in Paragraph 2.11 of the List establish a minimum retention period of seven years. If the store holds such documents, before destroying them, check that both the seven-year archival period and the 2,555-day tax period have expired, including all applicable extensions.

The notes, explained in Paragraph 2.11 of the List, extend retention for documents related to audits and appeals. They provide, among other things, for one year after the deadline for court appeal has passed, or, if an appeal is filed, one year after the decision concluding the case takes legal effect; if it is subsequently appealed, three months after the final decision that can no longer be appealed. Documents needed to substantiate claims for compensation for material damage should also be reviewed separately before being selected for destruction.

For a sole proprietor’s tax documents, Paragraph 1.4 of the List refers to the TCU. Therefore, the company’s five-year minimum should not automatically be applied to the entrepreneur’s entire tax archive. Other types of documents may have their own retention periods.

Recommended archiving procedure:

  1. Group documents by transaction, counterparty, and reporting period.
  2. For each category, record the applicable retention period, its start date, and any circumstances that extend it.
  3. Keep paper originals separate from working scans; retain electronic originals together with their signatures.
  4. Flag files related to audits, disputes, or claims for compensation.
  5. Check all periods and restrictions before destruction. For organizations, Paragraph 2.12 of the List prohibits destruction without a prior appraisal of the documents’ value.

For a sole proprietor subject to Procedure No. 496, the Inventory Records Form and documents for the goods must be available at the place of sale until the last unit listed in them is disposed of. Source documents must be grouped monthly in chronological order according to their entries in the Inventory Records Form and/or filed for later retention together with the relevant Form. Selling the last item in a shipment does not mean the documents can be destroyed.

What to do if documents are lost or damaged

General procedure: notify and restore

Under Paragraph 44.5 of the TCU, within five days of losing, damaging, or prematurely destroying documents, the taxpayer must notify the controlling authority where they are registered in writing. Submit the notice using the procedure established by the TCU for filing tax returns and attach documents confirming the event, prepared in accordance with the law. If relevant customs circumstances apply, also notify the customs authority specified in that paragraph.

The documents must be restored within 90 calendar days from the day after the notice is received by the controlling authority. Keep proof of receipt so you can determine the deadline correctly.

  1. List the missing documents, counterparties, transactions, and periods.
  2. Keep evidence of the cause of the loss and submit the notice on time.
  3. Request properly prepared replacement copies or duplicates from counterparties, obtain bank documents, and restore electronic originals from backups.
  4. Track the documents restored and check that they match the actual transactions and accounting entries.

For enterprises, Paragraph 6.10 of Regulation No. 88 also requires written notice to law enforcement, appointment of a commission, and a report listing the documents and reasons for their loss. Copies of the approved report must be sent to the recipients specified in that paragraph within ten days.

If the notice is properly and timely filed and the loss makes an audit impossible, Paragraph 44.5 provides for postponing the audit until the documents are restored and submitted within the prescribed limits, but by no more than 120 days. This rule does not apply to audits under Article 200 of the TCU. If the taxpayer fails to restore the documents, or loses, damages, or prematurely destroys them again after using this procedure, Paragraph 44.5 treats them as absent when the relevant tax return is prepared or when requirements of customs, currency, and other legislation monitored by tax authorities are fulfilled.

Special procedure for activity in designated territories

Subparagraph 69.28 of Paragraph 69, Subsection 10, Section XX of the TCU establishes an exception for taxpayers who carried on business in areas of active hostilities or temporarily occupied territories of Ukraine and cannot present source documents because of the related circumstances. Check the territorial criteria and the reason why the documents cannot be presented. For lost documents, the loss must be connected to hostilities. If documents remain in the relevant territories, the basis may be that they cannot be removed, that removing them would endanger people’s lives or health, or that authorities have imposed administrative obstacles. Martial law alone is not sufficient to use this exception.

The taxpayer files a notice in any form, stating the circumstances, tax periods, and a general list of documents, with identifying details where possible. For an enterprise, the provision requires the signatures of the head and chief accountant. If, after notifying the authority that documents cannot be removed, the taxpayer learns that they have been lost, a separate notice of loss must be filed.

For the periods specified in the notice, the controlling authority cannot challenge tax return figures solely because source documents are missing. The notice is also grounds for retaining expenses, a negative corporate income tax base, an input tax credit, and negative VAT amounts from prior periods without the supporting documents. After notice that documents cannot be removed because they are in designated territories, a moratorium applies to documentary audits for the specified periods.

After a proper notice of lost documents, those periods cannot be audited by the controlling authority, including after martial law ends. At the same time, for those periods the provision restricts increases to declared tax liabilities, a negative corporate income tax base, and VAT refunds from the budget.

The controlling authority must prove that the grounds for using the special procedure do not apply and, if refusing, issue a reasoned decision no later than one month after receiving the notice. The decision can be appealed administratively or in court. Until a final decision in the case, the authority cannot challenge tax return figures or initiate any audit concerning the periods stated in the notice. Unjustified use of the special procedure is treated by law as tax evasion and carries liability. This process must be assessed separately from the general “five days to notify and 90 days to restore” procedure.

How to provide documents during a tax audit

Under Article 85 of the TCU, after an audit begins, the taxpayer provides documents that fall within or relate to its scope. Requests for documents in cases not provided for by the TCU are prohibited. Copies are certified by the taxpayer’s or officer’s signature and a stamp, if available. Under Paragraph 85.4 of the TCU, an inspector must request copies no later than five business days before the audit ends.

Receipt of copies is documented by an inventory, a copy of which is handed to the taxpayer for signature. Documents containing trade secrets or confidential information are provided separately, identifying the officer who received them; their provision for review and return are documented by a report. Originals cannot be seized except in cases provided for by criminal procedure law.

In practice, designate one responsible person to track requests and documents provided. Prepare a linked set for each transaction: contract terms, receipt or transfer, payment, and accounting entries. Under Paragraph 12 of Article 3 of Law No. 265/95-VR, a sole proprietor required to keep inventory records must provide documents on the accounting and origin of goods held at the place of sale at the start of the audit.

Under Section II, Paragraph 11 of Procedure No. 496, the entrepreneur or the person actually selling the goods or conducting settlements must provide them. If the store does not hold the original source documents, copies may be provided, and the originals may be presented if needed before the audit is completed. The electronic Inventory Records Form must, at an inspector’s request, be displayed in a format that allows it to be viewed and/or copied.

Under Paragraph 44.6 of the TCU, failure to provide documents before the audit ends or within the deadlines in Paragraph 86.7 may mean they are treated as absent when the relevant tax return was prepared. The provision makes an exception for seizure or other removal by law enforcement. The controlling authority must consider documents provided after the audit and before a decision is made under Paragraph 86.7.

Under Paragraph 86.7 of the TCU, a taxpayer who disagrees with the audit findings or the facts and data stated in the audit report or certificate may submit objections, additional documents, and explanations within 10 business days from the day after receiving the report or certificate. A separate procedure applies to an unscheduled documentary audit under Subparagraph 78.1.5: under Subparagraph 86.7.4, the taxpayer may submit objections within five business days from the day after receiving the report or certificate.

The controlling authority does not consider these objections separately but attaches them to the audit or appeal materials and takes the stated facts and data into account when preparing its conclusion or considering the appeal. Keep proof of receipt of the report and submission of the documents to demonstrate compliance with the applicable deadline.

If the inspector refuses to consider documents, Paragraph 44.7 allows the taxpayer, before the audit ends, to submit certified copies directly to the controlling authority or send them by mail with delivery confirmation and an inventory of contents. If the taxpayer submits documents or mailed copies reach the authority less than three days before the audit ends, the audit is extended for the period specified in Article 82 of the TCU. If mailed copies arrive after the audit ends, the controlling authority may defer its decision on the audit results and appoint an unscheduled documentary audit.

Paragraph 121.1 of the TCU sets a penalty of UAH 1,020 for failing to retain specified documents for the required period and/or failing to provide originals or copies during tax control in cases provided for by the Code. For failure to provide documents, Paragraph 121.1 expressly excludes documents obtained from the Unified Register of Tax Invoices. For the same acts, if a penalty has already been imposed within the preceding year for the same violation, the amount is UAH 2,040. This sanction has specific legal grounds; an arbitrary typo in a delivery note is not, by itself, the violation described here.

How to prepare a delivery note and check payment in Torgsoft

Torgsoft’s official sales guide describes selecting a customer, adding goods from inventory, changing the quantity, and setting document parameters such as date, period, number, and enterprise. To prepare a shipment in practice, first select the actual buyer and selling enterprise, check the goods, quantity, and date, then open “Print” → “Delivery note.” The program lets you preview a delivery note, save it in an available format, or print it. Check the printed form’s details and the responsible persons’ information before signing.

In the “Document” menu, open “Trade with invoice issuing” and the “Customer payments” tab. Here you can match invoice and delivery note payments, find unidentified payments, and link them to invoices. This is useful for checking prepayments before shipment. Retrieving bank account statements in this mode is available when the additional “Bank statements for accounts” feature is activated. Verify that funds arrived against the bank data.

After creating a delivery note, arrange for it to be properly signed and retain the original. Printing or saving a file does not itself apply a QES, register a tax invoice, or satisfy all accounting archive requirements. A sole proprietor subject to Procedure No. 496 must also ensure that the Inventory Records Form and documents comply with that Procedure.

How to organize a daily check of store documents

  1. At receipt, an employee compares the actual goods with the document and immediately records any shortage, surplus, or damage.
  2. Before selling a new shipment, the responsible person checks the receipt documents and, if Procedure No. 496 applies, confirms that the entry has been made in the Inventory Records Form.
  3. When preparing a document, the employee checks the date, parties, content, quantity, units of measurement, and required signatures. Blank lines in paper source documents are crossed out in accordance with Paragraph 2.10 of Regulation No. 88.
  4. After a payment or return, the accountant matches the movement of funds to the relevant transaction and avoids recording the same document twice.
  5. Before the end of a reporting period, the accountant checks shipments, prepayments, and services received for which documents are missing.
  6. After processing, the responsible person transfers originals to the archive and checks that electronic documents and backups are accessible.

Official sources for checking document requirements

Torgsoft for accountants

See how stock, documents and payments are connected

The Torgsoft demo lets you reproduce typical store operations and review the data used by an accountant.

  • Stock movement Record goods receipts, sales, returns, write-offs, transfers and stocktakes.
  • Documents, payments and fiscal receipts Compare stock documents, payment methods, balances and linked fiscal receipts.
  • Multiple businesses Review how documents, fiscal registers, accounts and reports are separated between sole traders and legal entities.

Try it with your own example

The demo is available for 30 days. During a consultation, you can check whether Torgsoft fits your accounting workflow.

Add comment

Add comment
Thank you for your feedback! It will be published after being reviewed by a moderator.

Related articles