The number of high‑risk VAT payers is increasing. What does this mean for businesses right now?

In recent months, the tax authorities have continued to tighten control over VAT payers’ transactions. The number of companies included in the high‑risk list has increased again, and the number of blocked VAT invoices has also grown.

What does business need to understand?
Today, VAT risk status is no longer just an issue for “tax schemes”. Entirely real businesses can be classified as high‑risk due to their counterparties, staffing indicators, document flow specifics, or even a mismatch between the scale of operations and the company’s resources.

What are the consequences for business?
▪️ blocking of VAT invoices;
▪️ delays in input VAT credit for your clients;
▪️ additional requests and explanations from the State Tax Service;
▪️ risk of losing some counterparties who are unwilling to work with a company that has been placed on the high‑risk list.

Sometimes the issue lies not in the company itself but in the fact that the tax authorities see certain risks in the supply chain or transaction structure.

What comes next?
In my view, over the coming months we will see a further shift toward a risk‑based control model. The tax authorities will increasingly rely on automated data analysis, and the number of audits will be driven by the level of tax risk associated with the business.

As a result, tax security is gradually becoming just as important as sales and finance.

What do we recommend for businesses right now?
✅ Check whether your counterparties show signs of high‑risk status.
✅ Audit VAT invoices and transactions for recent periods.
✅ Assess whether staffing and physical resources are sufficient to support the declared business activities.
✅ Review contracts and documents related to lease, logistics, warehousing, and subcontractors.
✅ Prepare a document package in case your VAT invoices are blocked or your company is added to the high‑risk list.

To avoid unnecessary risks, businesses should proactively analyze their processes and evaluate the potential impact of new supervisory approaches.

If you have any questions or require a tailored consultation for your specific situation, the team at WINNER Law Firm is ready to assist.

Author – Maksym Bahniuk, Head of Tax and Customs Law Practice at WINNER Law Firm.
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