Can the controlling body conduct a tax audit of the declarant’s source of receipt of funds from which declared assets in the one-time (special) voluntary declaration were purchased?

Paragraph 13 Sub-section 9⁴ Section XX “Transitional Provisions” of the Tax Code of Ukraine as of 02.12.2010 № 2755-VI with changes and amendments (hereinafter – the TCU) stipulates that tax audit conducted by the controlling body is not carried out in relation to the individual’s or declarant’s source of receipt of funds at the expense of which declared assets were purchased or assets provided for in Paragraph 10 Sub-section 9⁴ Section XX “Transitional Provisions” of the TCU.

Herewith, Paragraph 10 Sub-section 9⁴ Section XX “Transitional Provisions” of the TCU determines composition and volume of assets, sources of receipt (acquisition) of which in case of the individual’s non- of the right to submit one-time (special) voluntary declaration are considered to be those from which taxes and levies have been paid in full amount according to tax legislation.