A no more “risky” tire manufacturer

Tax authority included a well-known international tire manufacturer to the risky taxpayers’ list. During the investigation, the Council found out that respective decisions on the payer’s riskiness contained only general statements and did not detail specific reasons.
The company also informed the tax authority suspended a large number of adjustment calculations, referring to the company’s compliance with risk criteria.
In particular, since the company allegedly did not provide source documents regarding its relations with counterparties. Despite the successful appeal of the regional level Commission’s decisions on the refusal to register adjustment calculations, the latter did not change its position regarding the large taxpayer riskiness.
BOC brought up the complaint for consideration by the Expert Group with the STS of Ukraine, as a follow-up of which the STS agreed with the unreasonableness of the decision on the taxpayer’s riskiness.
After the company submitted the requested documents to the tax office, it was excluded from the list of risky ones.