On 1 January 2019 Federal Law 231-FZ of 29 July 2018 will come
into force, enabling the tax authorities to request client-related
documents from auditors which constitute 'auditing
secrets'. This law's introduction will mark the end of
years of struggle by the Russian tax authorities to gain access to
audit documents.
Key changes
Since the Tax Code's adoption in 1999, the tax authorities
have had the right to collect from 'information sources'
(ie, not from audited taxpayers) the information necessary to
conduct a tax audit. However, an exception was made for information
which constitutes advocacy or auditing secrets. As such, the tax
authorities were prohibited from requesting such information from
lawyers and auditors, respectively. This ban will cease to be
effective with regard to auditors from 1 January 2019. At the same
time, the concept of auditing secrets provided for in the Law on
Auditing has been preserved. It is understood that any information
received
