Complaint against a decision on compliance with risk criteria

"Taxes are the price we pay for the opportunity to live in a civilized society".

Yasinskiy Yevhen

Head of tax law practice

An expert in the practice of tax law, specializes in the protection of rights in court, corporate law.

Contact now

Complaint against a decision on compliance with risk criteria

Reading time: 4 min.

If your company is included in the list of risky companies, this leads to a number of complications in your business. By the way, such complications affect not only you directly, but also, for example, your business partners in contractual relations, who will not be able to receive a tax credit when interacting with you. But this is not the end of all the challenges that begin when a company is included in the risky list. Being on this list is already the basis for further blocking of tax invoices. Thus, this problem, if left unresolved, creates a number of artificial problems and complications. Therefore, you should not waste time, you should contact specialists who know how to act in such cases and are able to provide professional legal support.

Get legal advice on the riskiness of the enterprise

What does point 8 in the list of company risk criteria mean?

The provisions of Procedure No. 1165, which was adopted by the Cabinet of Ministers on December 11, 2019, provide for 8 criteria for the riskiness of a taxpayer. These can be both obvious problems (such as invalid information provided during the company registration) and reasons that the tax authorities interpret rather subjectively. This is exactly what can be said about clause 8. It refers to the riskiness of a business transaction.

If we follow the letter of the law, then if the tax authorities consider a company to be risky based on this criterion, they would have to explain in detail why they consider the business transaction that led to this decision to be risky. However, practice shows the opposite. The company receives an artificially created problem, and representatives of the State Tax Service do not provide convincing explanations as to why it was included in the list of risky ones.

Why you should contact a lawyer right away

Our experience shows that it is difficult for taxpayers to solve such problems on their own. There have been numerous appeals when company management tried up to ten times to influence the situation on their own, but things only got off the ground after the intervention of specialists. So, let us tell you more about how we work in such cases. Everything happens in the following algorithm:

  • A detailed analysis of the company's status, fixed assets, tax payment history, staff, contractual partners, typical transactions, and industry specifics.
  • Writing an explanation to the State Tax Service based on all the analyzed information to remove the company from the risky list.

Once the issue is resolved, you can continue to register invoices without any artificial problems or complications.

Advantages of our work

Prikhodko & Partners Law Firm specializes in tax law and knows how to help its clients with such requests in a truly efficient and effective manner. Writing appeals against decisions on compliance with the riskiness criteria is one of the key focuses of our team's practice in the field of tax law.

Calculate the cost of a lawyer's assistance in challenging the riskiness of an enterprise

If you are faced with such a problem, you should not delay its resolution. Turn to those who can effectively influence it and do everything necessary in the legal field so that your company can continue its business activities unhindered. You will meet such experts at our law firm. They do their job diligently and help client companies to establish more constructive interaction with the State Tax Service.

Calculate the price of assistance:

1 question

Have other lawyers handled your case?


2 question

Are you in Kyiv or Kyiv region?


3 question

Do you need legal assistance urgently?


Head of tax law practice

An expert in the practice of tax law, specializes in the protection of rights in court, corporate law.

Contact now
How helpful was the article? Rate:


Count of grades:


If we do not
call back
during the day
Law Company
Leave a request for legal assistance right now:
The best lawyers
Fair price
We work quickly
Online / offline consultation