Removal from the risky‑taxpayer list: effective solutions for your business

For a business, the status of a “risky taxpayer” is essentially a red card from the tax authority. VAT invoices are blocked, supply chains are disrupted, partners are afraid to work with you, and every transaction is automatically treated as suspicious. At the same time, the formal wording in the tax authority’s decisions rarely makes it clear why exactly you were classified as risky and what needs to be fixed.

Many companies try to “get out of risky status” chaotically: they send documents without a system, write emotional explanations, randomly change NACE codes or contract terms. As a result, months go by, the decision does not change, and the business continues to operate in a mode of constant invoice blocking and counterparty distrust. At WINNER we treat this issue as a comprehensive project: it is important not only to change your status with the tax authority, but also to build a working model that will not push you back into the risky list.

What being a “risky taxpayer” means in practice

Risk status is not just a mark in the system. It entails:

• systematic blocking of VAT invoices, including for fully real transactions;
• increased scrutiny of your counterparties and, as a result, loss of some partners;
• higher probability of audits and information requests;
• reputational risks: banks, large companies and public customers are reluctant to work with risky suppliers.

Ignoring this status means accepting that your business will constantly operate “through obstacles”. That is why it is crucial to understand clearly which criteria led the tax authority to classify you as risky and which steps actually influence the commission’s decision.

How WINNER helps businesses leave the risky‑taxpayer list

We do not start with “filing papers”, but with diagnostics.

Our work usually includes:

• Analysing the tax decision and criteria.We study the specific point under which you were classified as risky, the arguments used by the tax authority and whether there were any procedural violations.
• Assessing the business model.We look at which transactions, supply chains, counterparties and internal processes could have triggered the decision: transit‑type flows, weak spots in documentation, mismatches between real operations and your registered NACE codes, etc.
• Designing an exit strategy.We determine what must be changed: replacing certain counterparties, strengthening documentation of transaction reality, adjusting NACE codes, updating contracts, demonstrating the “resource backing” of your activity (staff, fixed assets, warehouse capacities).
• Preparing the document and explanation package.We collect and structure evidence of real business activity: contracts, primary documents, information on staff, assets, production or warehouse facilities, photo and other proof. We draft clear explanations addressing precisely the concerns the tax authority has.
• Appeals and ongoing support.We file documents with the commission, manage communication and, in case of refusal, prepare administrative appeals and court claims where appropriate.

The key goal is not to “bombard” the tax office with paperwork, but to demonstrate that your business is real, transparent and controllable.

What changes after leaving the risky list

Once the risky‑taxpayer status is removed, the business returns to normal mode:

• invoices are registered without systematic blocking;
• partners feel more comfortable working with you, reputational doubts recede;
• operational costs for constantly “putting out fires” with VAT invoices are significantly reduced;
• you can focus on growth instead of endless correspondence with the tax authority.

At the same time, we always recommend not stopping at the mere fact of being removed from the risky list. It is important to lock in the result in your processes: set up counterparty checks, standardise document flows and correctly allocate roles in the team for VAT and invoice compliance.

Why you should turn specifically to WINNER

WINNER is a law firm with a team of 20 attorneys and lawyers who work every day with tax risks, VAT invoice blocking and disputes with the tax authorities. We take on cases where businesses are already exhausted by unsuccessful attempts to leave the risky‑taxpayer list and build a systematic approach — from root‑cause analysis to changing tax commission decisions.

We work with companies and entrepreneurs across Ukraine and in different industries — from trade and manufacturing to services and IT. If your business has been included in the risky‑taxpayer register and you need not just “one more submission” to the tax authority but a real exit strategy, contact WINNER — we will analyse your situation and propose a solution that allows you to return to normal operations.

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