STS Audit Plan 2026: Who Is in the High Tax Risk Zone

At the end of the year, businesses are expecting a new audit schedule that will show how the State Tax Service (STS) builds its control strategy: instead of “total” audits, priority will be given to taxpayers with elevated risks. After years of moratoria and restrictions, business is moving into a more flexible and analytical control model, where the tax authority shifts to a risk‑based approach relying on large data sets from the Unified Register of Tax Invoices, cash registers, banking reports, automatic exchange of information and sectoral analytics. The 2026 audit schedule is becoming one of the key indicators of this transition.

What “focus on high tax risks” means.  Although the risk‑based approach is already enshrined in the Tax Code and secondary legislation, the practical meaning of the term “high tax risks” for business still remains rather abstract. In 2026 increased attention should be expected to the following areas:

• significant discrepancies between declared indicators and data from other sources (customs, banking operations, counterparties’ data, international information exchange);
• systematic declaration of losses or minimal profit while turnover and assets are in fact growing;
• active use of “risky” counterparties, sham transactions, unreal supplies and VAT fraud schemes;
• aggressive tax planning models, in particular involving non‑residents, CFCs, indirect payment of dividends and royalties;
• industries traditionally considered sensitive to shadow schemes – fuel trade, scrap metal, high‑margin import, the IT sector with elements of tax optimisation, construction, and agriculture with a large volume of cash turnover.

In essence, the STS concentrates its resources not on formal “box‑ticking” but on taxpayers with the greatest potential for additional assessments, which, under martial law and limited resources, logically shifts the focus to the efficiency of each audit.

How the audit schedule is formed and why someone “ends up on the list”.  In general terms, the process can be described as follows:

1. Analytics of returns and reporting.
   Automated STS systems detect atypical or suspicious patterns: sharp jumps in input VAT, abnormal ratio of income to expenses, systematic amended returns with negative adjustments, changes in the business model without economic justification.
2. Cross‑checking of data.
   Correlations are checked between your indicators and the data of counterparties, customs, financial institutions and the statistical authorities. Any persistent discrepancies can increase a taxpayer’s “risk rating”.
3. Information from international sources.
   Automatic exchange of tax and financial information under the CRS standard, data on CFCs, ownership structures abroad and payments of passive income (dividends, interest, royalties) to non‑residents are playing an ever greater role.
4. Sector‑specific approaches.
   For certain sectors (for example, fuel, agriculture, construction, e‑commerce) the STS uses its own “risk profiles” based on average industry profitability, wage levels, the volume of cash settlements, etc.
5. Previous history of relations with the tax authorities.
   Frequent audits, significant additional assessments in past years, court disputes, refusal to provide documents or admit inspectors – all this increases the likelihood of being included in the plan again.

For businesses it is important not only to check the mere fact of being included in the audit schedule, but also to honestly assess which exact indicators or transactions could have triggered a “red flag” for the tax authority.

Wartime context: will there be more audits in 2026.  The wartime context will continue to shape tax control: the state will seek additional revenues without increasing rates, while avoiding excessive pressure on compliant businesses. The 2026 audit schedule is unlikely to return to pre‑war volumes; however, the quality of audits and depth of analysis will increase as the STS more widely uses analytical tools. A separate focus will be on companies that appear stable or are growing during the war but declare minimal taxes, for which the status of “high” tax risk becomes almost inevitable.

Which taxpayers are in the high‑attention zone.  In 2026 several conditional groups of taxpayers can be distinguished, for which the risk of a scheduled documentary audit will be higher than average:

• large businesses and corporate groups with extensive supply chains, transactions with non‑residents and intra‑group pricing;
• VAT payers with active “chains” and a significant amount of input tax, especially on transactions with counterparties that show signs of risk;
• businesses with a high share of cash settlements, including retail trade, public catering and certain service segments;
• companies with regular losses or zero profitability that are at the same time actively investing, holding substantial assets or increasing their staff;
• taxpayers with an international component, including ownership of foreign companies, CFCs, foreign bank accounts and transactions with crypto‑assets.

This does not mean that all such entities will necessarily appear in the plan, but these factors are often decisive when STS allocates its resources.

Defence strategy: what should be done now.  For taxpayers seeking to minimise the risk of additional assessments, it is advisable to:

1. Conduct an internal tax audit of key taxes.
   Special attention should be paid to VAT, corporate income tax, personal income tax and military levy, unified social contribution, as well as transactions with non‑residents and payments of passive income.
2. Assess the company’s “risk history”.
   Analyse past audit reports, court decisions, STS requests, blocked tax invoices, and risky counterparties. This will help you understand where exactly the tax authority may look for “weak spots”.
3. Review the structure of counterparties.
   The presence of repeatedly used “dubious” partners, technical companies and sole proprietors who in fact perform the functions of employees are classic targets for additional assessments.
4. Strengthen the documentary evidence of real transactions.
   Proper contracts, primary documents, acts, specifications, technical assignments, correspondence, logistics documents and evidence of arm’s‑length pricing are the first line of defence in any audit.
5. Reconsider international structuring models.
   Given CRS information exchange, CFC rules and the “business purpose” test, old optimisation schemes may create more risks than savings. By 2026 the structure should be brought into line with current approaches.
6. Prepare a “taxpayer dossier” for an audit.
   This may be an internal package of documents and explanations containing a concise description of the business model, the group structure, key contracts, transfer pricing policy and the company’s position on controversial transactions. This approach allows you to face an audit in a maximally controlled format.

Why it is important to act proactively.   The 2026 audit schedule is not just a list of companies that were “lucky” or “unlucky” to find their name in the public register. It is a reflection of how the state perceives the risks of your business. The sooner a company starts to work with these risks, the lower the chances of a conflict scenario with additional assessments, penalties and blocked operations.

A proactive stance means:

• not waiting for a request or audit order, but independently identifying weak spots;
• documenting your tax position before a dispute arises (in internal memos, explanatory letters, communication with counterparties);
• treating tax risks as part of the overall business management strategy, and not as a “one‑off problem” to be solved only at the time of an audit.

If you have questions or issues related to scheduled tax audits, tax risk assessment or preparation for interaction with supervisory authorities, seek professional advice — timely analysis of the situation will help reduce the risk of additional assessments and protect your business interests.

Author: Ihor Yasko, Managing Partner at “WINNER” Law Firm, PhD in Law.