As a general rule, the tax authorities are not entitled to request additional information and documents in the course of a desk audit (paragraph 7 of Article 88 of the Tax Code of the Russian Federation). But the Tax Code contains exceptions:

For example, if in accordance with paragraph 8.1 of Art. 88 of the Tax Code of the Russian Federation, the information on transactions reflected in the VAT return, contradict each other or do not correspond to the data on the same transactions, which are contained in the declaration of counterparties, the log of received and issued invoices and such contradictions or inconsistencies indicate an understatement of the amount of VAT payable to the budget, or an overstatement of the amount of VAT claimed for refund, the tax authority has the right to request from the taxpayer invoices, primary and other documents relating to the above transactions.

In its letter No. EA-2-15/10152 dated 12.07.2024, the Federal Tax Service stated that the tax legislation does not contain any restrictions on the scope and composition of the documents to be requested. A tax authority official independently determines the scope of documents and the relation of particular documents (information) to the taxpayer’s activities.