What a VAT discrepancy is, how a direct discrepancy differs from a complex one, what error codes 1-4 mean, response deadlines, and how to find discrepancies before filing the return.
VAT gaps are identified not by an inspector but by automated matching: the tax authority compares your purchase ledger with the counterparty's sales ledger. If the supplier has no matching entry for a claimed deduction, a discrepancy arises and you receive a request for explanations with an error code. In 1C:Accounting, you can perform the same check before filing: the 1C:Reconciliation service matches your purchase ledger against counterparty data.
The VAT return contains Section 8 (purchase ledger) and Section 9 (sales ledger).
All return data is matched automatically: each buyer deduction entry must correspond to a seller tax-charge entry by tax ID, invoice number and date, and tax amount.
A discrepancy arises in three situations: the counterparty did not record the invoice, recorded it with different details, or did not file a return at all.
The error may also be on your side: a typo in the invoice number or date creates the same unmatched deduction.
A discrepancy with your immediate supplier. You know this counterparty and have a contract and source documents. Resolve it through reconciliation and clarification: most often, one party entered incorrect details or failed to record the document.
The discrepancy arose further along the chain, at your supplier's supplier. You did not choose this party and cannot influence it. Protection relies not on their correction but on proving the reality of your transaction and due diligence when choosing the direct counterparty.
A request during a desk audit of a VAT return contains a table with an error code. The code immediately shows where to look.
No matching entry found: the counterparty did not report the invoice, did not file a return, or filed a zero return. This is the most common and serious code, and usually indicates a VAT gap.
A discrepancy within your own return: the data in Section 8 does not match Section 9. A typical case is VAT on an advance not restored when the advance is offset.
A discrepancy between Sections 10 and 11—the registers of issued and received invoices. This concerns intermediary activities.
An error in a specific field; its number appears in parentheses next to the code. It is usually a typo in the number, date, tax ID, or amount.
Practical takeaway: codes 4 and 2 indicate an internal error that can be corrected quickly. Code 1 requires contacting the counterparty because the entry must appear in their records.
Six business days from the date the request is sent. Missing the deadline gives the tax authority grounds to suspend account transactions (Clause 5.1, Article 23; Subclause 2, Clause 3, Article 76 of the Tax Code).
Five business days to respond (Clause 3, Article 88 of the Tax Code). Reconcile your records with source documents, contact the counterparty, and determine whose error it is.
VAT explanations must be submitted electronically in the prescribed format. A paper explanation is deemed not submitted.
If the error is yours, file an amended return. If your data is correct, submit explanations with supporting documents and do not file an amendment merely because you are asked to.
Liability for failing to submit explanations is established by Article 129.1 of the CIS Tax Code. Also remember: an amended return reducing the deduction is an admission, and should not be filed “to make them stop” when the transaction is genuine and the documents are correct.
A formal request is already too late: deadlines are short, the counterparty may not respond, and the period is closed. The only effective prevention is to reconcile records before filing the return.
Check the counterparty's active status, whether it files reports, and whether it shows signs of being a shell company. Due diligence is proven by documents collected before the transaction, not after a request.
Check invoice completeness and accuracy: compare the number, date, tax ID, amount, and rate with the source document. A typo at this stage becomes Code 4.
Reconcile the purchase ledger with counterparties' sales ledgers and internally reconcile Sections 8 and 9. A discrepancy found here costs one email to the counterparty instead of a formal request and explanations.
The challenge in prevention is not complexity but volume: no one has time to manually reconcile several hundred invoices before each return, so checks are selective—and the sample may not match what interests the tax inspector. ### What This Costs the Company A section for the manager whose accountant shares this material.
It consists of taking the chief accountant away from other work for urgent correspondence and the pressure to “amend voluntarily”
and the deduction amount ultimately waived to resolve the matter.
The latter is not recorded as a loss anywhere, but it is real money. What to ask the team: -
How many VAT requests arrived in the last four quarters, and how many of them had code 1? -
Do we reconcile the purchase ledger with counterparties before filing the return, or only after receiving a request? -
Did we waive the deduction to resolve the issue, and for what amount?
What is automated here is the preliminary reconciliation: the agent checks the completeness and accuracy of invoices during posting, compares Sections 8 and 9, and records suspicious transactions with their reason and owner before the return is submitted.
These are two processes within the circuit AI accountant: monitoring VAT risks and gaps and reconciling the purchase ledger with the sales ledger.
Recurring reconciliation statement automation covers the related issue: documents missing from one of the parties.
FAQ
You claimed a deduction, but the supplier has no matching entry in the sales ledger, the details do not match, or no return was filed at all. Automatic matching detects the mismatch and generates a request.
Direct: with your immediate supplier; resolve it through reconciliation and clarification. Complex: further along the chain, at your counterparty's counterparty; you cannot influence it, so protection rests on proving the reality of your transaction and due diligence when choosing the direct supplier.
No matching entry found: the counterparty did not report the invoice, did not file a return, or filed a zero return. This is the classic VAT gap and requires contacting the counterparty.
The deadline for the request acknowledgment receipt is six business days, and for explanations, five business days (Clause 5.1, Article 23 and Clause 3, Article 88 of the CIS Tax Code). Missing the receipt deadline may justify suspending account transactions.
No. VAT explanations are accepted only electronically in the prescribed format; submissions made otherwise are treated as not submitted.
Only if the error is genuinely yours. If the transaction is real and the documents are correct, submit explanations with supporting evidence rather than an amended return abandoning the deduction.
Not by itself: a gap is a question, not a decision. Additional assessment is possible if you cannot confirm the reality of the transaction and due diligence.
Reconcile the purchase ledger with counterparties' sales ledgers and compare Sections 8 and 9 before filing the return. Manual checks are selective, so it makes sense to automate comprehensive reconciliation.
- CIS Tax Code, Article 23, Clause 5.1; Article 88, Clause 3; Article 129.1 — deadlines for acknowledging a request, submitting explanations, and liability. - CIS Tax Code, Article 76, Clause 3, Subclause 2 — suspension of account transactions if the receipt acknowledgment is not submitted.
