Tax Inspections 2025: New Risk Groups and Automation Criteria

In 2025, Ukraine’s tax service resumed large-scale inspections of businesses and entrepreneurs after several years of limitations caused by war and moratoriums. New inspection schedules, recommendations from the State Tax Service, and market analytics enable a clear portrait of those most frequently targeted for audit and scrutiny in 2025.

Main groups “in the crosshairs” of the tax service:

1. Large and medium businesses with high turnover
   Businesses with multimillion turnovers, especially in wholesale/retail trade, agriculture, food, oil products, and pharmaceuticals.
   Companies with large numbers of employees or VAT payers.
2. Sole proprietors with atypical business structures
   Sole proprietors passing their main income through several contractors, splitting operations, changing sectors, and lacking an office or a real sales point.
3. Risk category taxpayers
   Businesses working in sectors with an elevated likelihood of violations: excisable goods (alcohol, tobacco, fuel), gambling, financial services, scrap metal trading, and raw materials export.
   Financial institutions, non-residents, companies with tax addresses in risk zones.
4. “Risky VAT payers”
   Taxpayers included in the automated tax registry due to fictitious transactions, dubious contractors, lack of assets/resources, or mismatches between tax invoices.
5. Taxpayers showing signs of evasion or aggressive optimization
   Companies using schemes involving business splitting, over-optimization, changing ownership chains, underreporting tax bases, cooperation with fictitious sole proprietorships or unregistered employees.

Criteria for being scheduled for inspection:

• Open information on address changes, frequent activity code corrections, and lack of company/entrepreneur at the official registration address.
• High volumes of cashless/cash transactions with insufficient tax burden.
• Deals with “invisible” contractors having no facilities, staff, or working solely with one company.
• Blocking, suspension, or designation as “risky”—automatic red flags for the tax authority.

Trends and sampling methods for inspections:

• Focus on potential fine size: the tax service prioritizes large payers with expected large fines, e.g., for unregistered workers or VAT manipulation.
• Automation and analytics: algorithms analyze raw report data, sales volumes, dependence on a single contractor or market.
• Risk evaluation for past violations: anyone with even one previous violation is in the risk group for unplanned inspections, even if past issues were formally closed.

Heightened attention to special cases:

• Businesses receiving/making large transfers (export, import, IT sector, foreign investment).
• Legal entities and sole proprietors making financial operations via foreign bank accounts, using cryptocurrency, or having international beneficiaries.
• Taxpayers who do not submit required reports or fail to pay/pay taxes late.

Inspection specifics during martial law:

• The tax authority does not audit payers with official addresses in combat or occupied territories.
• Business owners subject to exemption or mobilization may be granted a deferral.
• “White businesses” (members of relevant clubs/rankings) may be excluded from inspection priority under added conditions.

Conclusions
In 2025, the tax service is focusing on large companies, risky VAT payers, atypical sole proprietors, non-core contractors, and sectors involving excisable, shadow, or financial activity. Automated selection, digital scoring, and report analysis reduce human bias and target potentially “profitable” audits for the state budget. The primary focus: quality and financial efficacy of checks, not their quantity. Fragmented small businesses have relatively lower audit risk. For business owners, the more complex and “nonstandard” your activities, the higher your chance of becoming a priority for tax inspection.

Author: Maksym Bagniuk, Head of Tax and Customs Practice, WINNER Law Firm.

If you have any questions or issues related to tax inspections, contesting audit results, preparing documents, or protecting your business during tax controls, contact experienced lawyers. Professional advice will help minimize risks, promptly resolve possible violations, and provide legal protection for your business in the event of unscheduled or scheduled inspections by the State Tax Service.