Tax Audits 2026: Business Rights and Avoiding SFS Fines

Tax audits in Moldova: the essential response

• Verify the legal basis, type, subject, period and authority of the officials involved.
• Appoint one coordinator and keep an inventory of every document provided.
• Supply accurate information within lawful deadlines while retaining context and exact copies.
• Distinguish the audit report, the decision on the case and the later appeal process.
• Objections should rely on primary records and calculations, not a general statement of disagreement.

Before the audit: define the procedural scope

Read the decision or other instrument authorising the action. Record the authority, audit type, taxes and period under review, location, officials and stated deadlines. Verify officials' service details and share the initiating papers with management, the accountant and responsible counsel.

Not every contact from the State Tax Service is an on-site audit. An information request, tax visit, desk review and operational control have different legal settings. The company's response should match the actual procedure instead of assuming that the whole business is being inspected.

Create an electronic file and chronology for incoming documents, requests, replies, meeting notes, copy inventories and explanations. This discipline prevents different employees from giving inconsistent versions and makes it possible to reconstruct the case when objections are prepared.

Preparing and transferring documents

The package depends on scope and may include primary accounting records, contracts, invoices, tax returns, ledgers, payments, inventory and employment records or electronic data. Do not create records retrospectively or alter originals outside a transparent accounting correction process.

Use a cover inventory for every transfer: title, date, number, format, page count and channel. Retain an exact copy of the set received by the inspector. Where commercial secrets, personal data or third-party information are involved, assess the lawful access regime and a secure method of delivery.

If a request is unclear or appears broader than the audit subject, ask for written clarification. That is not refusal to cooperate. It helps the company answer the lawful request completely while preserving evidence of what was requested and produced.

Conduct during the inspection

The coordinator accompanies officials, records questions and allocates preparation of responses. Employees should know not to conceal documents, argue emotionally, guess an answer or sign text they do not understand. If a fact is unknown, verify it against the records before responding.

Read each protocol and report before signature. Check dates, amounts, the list of copied or removed material and factual wording. If the company disagrees, use the available mechanism to record comments and request a copy. The meaning of a signature depends on the document and applicable procedure.

Build the company's position in parallel. Link each explanation to a primary record, accounting entry and legal provision. Confirm a material oral explanation in writing when it can affect the treatment of a transaction.

Report, decision and challenge are separate stages

At completion, review not only the total but the method: selected transactions, overlooked records, calculation of the base and grounds for sanctions. A table can map each issue to the SFS finding, company position, evidence, calculation and applicable rule.

The audit report records results, while legal effects and challenge routes depend on subsequent procedural documents. Do not miss the periods stated in them. Current appeal rules should be checked against the Tax Code in force and the document received, not an old checklist.

An effective objection is specific. It identifies the incorrect factual premise, the document that disproves it and the resulting change in calculation. Independent grounds should be stated separately.

Common business mistakes

• several employees respond without one register or common position;
• files are submitted without an inventory and cannot later be identified;
• explanations conflict with the accounts or contractual terms;
• objections are drafted at the last moment without an alternative calculation;
• the audit report is treated as a result that can no longer be challenged;
• the underlying process defect remains uncorrected after the audit.

Even a modest disputed amount may reveal a recurring recordkeeping defect that creates exposure in later periods. The outcome should therefore include both the legal response and an internal remediation plan.

Safe audit-support checklist

1. Verify the basis and limits of the audit.
2. Appoint a coordinator, lawyer and responsible accountant.
3. Create a chronology and document inventory.
4. Respond in writing and preserve delivery evidence.
5. Record comments on protocols and obtain copies.
6. Analyse every finding through facts, law and calculation.
7. Confirm the correct deadline and appeal route.
8. Remedy the internal process that caused the issue.

Legal support is particularly important for significant assessments, operational blocks, removal of materials, alleged repeat breaches, challenges to transaction reality or potential management liability. Counsel's role is to maintain procedural discipline and a verifiable position, not obstruct a lawful audit.