State Tax Service proved in the Supreme Court right to use tax information from the RRO Data accounting system during audits

Controlling authorities may use tax information contained in the Data accounting system of registrars of settlement operations (abb. RRO Data accounting system) during actual audits. This legal position was formed by the Supreme Court in its Resolution as of 07.08.2025 in case № 280/6835/23. 

Analyzing requirements of the Tax Code of Ukraine, the Supreme Court pointed out the possibility of using tax information received from taxpayers through databases of information, telecommunications and information and telecommunications systems during actual audits, particularly regarding: 

financial and economic transactions;

RPOPRRO use,

electronic copies of settlement documents and fiscal reporting checks submitted through the information system to the RRO Data accounting system; 

other information contained in the RRO Data accounting system.

Such data may be independent basis for conclusions during actual audit. 

Therefore, use of such information is a proper implementation of the tax control function.

The Supreme Court, while assessing legal relations regarding the appointment procedure, actual audit and registration of its results, confirmed the controlling authorities’ right during such audit to verify compliance with settlement procedure by business entities for the entire period under audit.

It is worth emphasizing that the State Tax Service carries out tax control taking into account decision of the National Security and Defense Council to introduce legal and organizational measures regarding a moratorium on groundless audits and interference by the state bodies in business activities, and exclusively on the basis of a risk-oriented approach and in the presence of high levels of risk.