The FTS flags companies for audit with a risk-scoring model long before it opens one. Whether you're already flagged, what a desk or field audit examines, and how to respond so it confirms rather than uncovers, is what this comes down to.
Your indicators match the FTS risk model — low margins, VAT refunds, related-party flows, sector patterns. Flagging comes before the audit.
Checking your exposure against the model before an audit opens, and readying the documentation so the audit confirms your position rather than finding gaps.
A Russian tax audit (налоговая проверка) for a foreign-owned company is rarely a surprise in retrospect — the FTS uses a risk-scoring model that flags companies well before inspectors arrive. Understanding the types of audit, what triggers them, what rights you have during them, and how to respond to document requests and acts is the best preparation for handling one constructively. This guide covers the 2026 framework.
A desk audit is an automatic, document-based review of a submitted declaration. It is conducted at the FTS office — not at the company's premises. Every declaration submitted triggers a desk audit. Key parameters for 2026:
Timeline: 3 months from the date of declaration submission (reduced to 1 month for VAT declarations where the FTS detects no errors). If a revised declaration is submitted during the audit, the clock resets.
Scope: limited to the specific tax and period covered by the declaration. The FTS can request documents and explanations (пояснения) within the audit period.
New from 2026: the FTS can now conduct desk audits from any regional inspectorate, not only the one at the company's registered address — cross-regional desk audits are explicitly permitted.
No notice required: unlike field audits, the company is not formally notified at the start of a desk audit. The first contact is usually a request for documents or explanations.
A field audit is a comprehensive review conducted at the company's premises (or, if the company doesn't have suitable space, at the FTS office). It is the most serious type of audit and covers up to 3 calendar years preceding the year of audit decision.
Pick your situation — we'll tell you where you stand:
Timeline: standard duration 2 months, extendable to 4 months (and in exceptional cases 6 months) by decision of the regional FTS.
Suspension: the audit can be suspended (приостановлена) for document requests to counterparties, translation, or expert review — suspension time does not count against the clock. Total suspension cannot exceed 6 months.
New from 2026: the FTS can now conduct seizure (выемка) during the consideration of audit materials — not only during the active audit period itself. This extends the window for document seizure.
Witnesses: the FTS can now summon witnesses through the Gosuslugi portal, not only by paper notice.
Moratoriums: some categories of companies have had field audit moratoriums imposed (and occasionally extended) by presidential decree — primarily small businesses and IT companies. Foreign-owned LLCs generally do not benefit from these moratoriums; confirm current status for your specific entity type.
The FTS uses a published 12-criterion risk model for field audit selection. For foreign-owned companies, the most commonly triggered criteria are:
Tax burden below industry average — if CIT/revenue ratio is lower than the published average for your OKVED sector;
Losses in two or more consecutive years;
VAT deduction ratio above 89% of assessed VAT;
Significant deductible expenses — particularly management fees, royalties or interest to related foreign parties;
Salaries below regional average — signals possible grey payroll;
High-value transactions with related parties — triggers TP review;
Frequent counterparty changes or dealings with known "fly-by-night" contractors;
Failure to respond to desk audit inquiries.
The FTS's risk-scoring has become increasingly automated in 2025–2026 — algorithms now flag declarations and identify anomalies with minimal human review until a decision is made to escalate to a formal audit.
Russian tax law grants taxpayers meaningful procedural rights during an audit. For foreign-owned companies, the most important:
Right to be represented: a company representative (in-house or external adviser) can participate in all audit procedures — inspections, document requests, witness interviews. External advisers with a power of attorney have the same rights as in-house legal counsel.
Right to contest document requests: the FTS can only request documents relevant to the audit scope. Documents outside the declared period or outside the declared tax can be refused. Track every request in writing.
Right to submit objections: after the audit act (акт проверки) is issued, the company has 1 month to submit written objections. This is one of the most important procedural steps — objections that are not raised at this stage are harder to raise in subsequent appeals.
Right to participate in consideration of the audit: the company must be notified of the date and time of the consideration of the audit materials. Participation in this meeting is strongly recommended.
A risk-scoring model flags companies before an audit opens — indicators like unusually low margins, VAT refunds, related-party transactions and sector patterns. Checking where you sit against the model is what lets you prepare before, not during, an audit.
A desk audit reviews a specific return or refund; a field audit is broader, covering multiple taxes and years on-site. Both look at the tax base and the documentation behind it — preparing to that standard is what keeps the audit a confirmation.
Yes — through the objection window, administrative appeal and ultimately the court. Many findings reduce before a judge, so a finding isn't final if you respond in time and on the right grounds.
This explains that a Russian tax audit is rarely a surprise — the FTS flags companies with a risk-scoring model well before it acts. Your question is whether you're already flagged, what a desk or field audit will look at, and how to respond so it confirms rather than uncovers.
Sense an audit coming, or already in one? The earlier we're involved, the more room there is to shape the outcome.
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