The State Tax Service Specifies The List Of Grounds For Determining A Taxpayer As A Risky One

On 5 March 2025, the State Tax Service issued Order No. 195 “On Amendments to the Order of the State Tax Service dated 11.01.2023 No. 17”, which updated the Codebook of Tax Information Codes, Which Is The Basis For Deciding On The Compliance Of A VAT Payer With The Riskiness Criteria Of A Taxpayer, used by the State Tax Service commissions when considering the compliance of a taxpayer with the riskiness criteria.

In particular, new codes have been introduced that will apply:

• transactions for the procurement of large volumes of services or works without real conditions for their performance;
• involvement of VAT non-payers in transactions without the necessary resources to perform the said works;
• exports of goods of unknown origin under the regime of export security (RES);
• absence of the taxpayer at the tax address, which makes it impossible to conduct a documentary audit.

The amendments will also clarify the tax information codes that do not apply to producers or service providers (or, on the contrary, are used only for these categories of taxpayers) and the period of analysis of transactions with risky counterparties, which will include only those transactions that were made not earlier than the decision on the riskiness of the counterparty.