The State Tax Service is moving to a systematic analysis of tax risks: what this means for businesses

On 19 August, the State Tax Service of Ukraine once again drew businesses’ attention to the implementation of a tax risk management system, known as compliance risk management. This is part of the National Revenue Strategy through 2030.

It is important to understand that the tax authority’s approach itself is changing.

The State Tax Service is gradually moving away from a model in which the supervisory authority reacts only to a specific violation, towards a model where a taxpayer’s risks are analysed systematically.

The tax authority identifies four main categories of risks:
— risk of taxpayer registration;
— risk of late filing or failure to file reports;
— risk of incorrect or incomplete tax reporting;
— risk of late tax payment.

This is an important signal for businesses.

What matters now is not only whether a company has committed a specific violation.

A company’s overall tax behaviour also matters: how it reports, what it declares, how it pays taxes, whether its actual activities correspond to its registration data, and where the system identifies potential risks.

At the same time, Resolution No. 854 does not establish any new obligations or restrictions for taxpayers. Officially, the State Tax Service promotes a preventive approach: consultations, explanations, and an opportunity for taxpayers to adjust their conduct come first, while audits are intended as a last resort.

However, the practical conclusion for businesses is different: it is important to understand how your company appears through the eyes of the State Tax Service’s system before an audit arises.

This is especially relevant for companies with substantial input VAT credits, complex transaction structures, numerous counterparties, non-standard financial flows, or significant fluctuations in their tax burden.

Therefore, a tax audit today is no longer merely a search for mistakes already made.

It is an opportunity to identify in advance the risks that the State Tax Service may identify tomorrow.

Primary source: State Tax Service of Ukraine, 19 August 2026.

WINNER Law Firm conducts tax audits for businesses, assesses high-risk transactions and business models, supports tax audits, challenges tax assessment notices, and protects companies’ interests in disputes with the State Tax Service.

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Author: Ihor Yasko, Managing Partner of WINNER Law Firm, PhD in Law.