An unannounced tax audit (control inopinat) is conducted without prior notice, unlike a full tax inspection, which is usually planned and announced in advance.
Legal Basis
According to Article 134 para. (1) of the Fiscal Procedure Code, tax authorities can carry out an unannounced audit to:
- check facts and documents based on information about violations of tax law;
- verify a taxpayer’s documents in correlation with others (cross-checking);
- assess taxable base elements or specific tax risks.
The audit duration is decided by the audit authority’s head and cannot exceed 30 days.
Closure of the Audit
Upon completion, a report is issued and delivered to the taxpayer, who has 5 working days to submit a response.
❗ Not Performed During Full Tax Inspections
An unannounced audit cannot run concurrently with a full tax inspection for the same obligations unless additional verifications are required by the tax inspectors themselves.
Key Rules for Conduct
- Tax officers must present ID and service order;
- The audit is registered in the unique control log;
- Tax documents are reviewed, including from the standard control file;
- Business locations are inspected;
- Written explanations can be requested from the taxpayer or third parties;
- Taxpayers may collaborate and seek legal assistance;
- The audit usually takes place at the tax office but can occur at the taxpayer’s premises;
- If no suitable space is available, the audit happens at the tax office or another agreed location;
- Authorities can inspect taxable assets and locations;
- Precautionary measures and seals may be imposed;
- Findings may be forwarded to criminal prosecution bodies;
- The report must be signed by both parties or only by the authority if the taxpayer refuses;
- Once a case is referred to prosecutors, the unannounced audit ends for that period but may resume if prosecution is dropped.