Why should a compliant taxpayer bear tax consequences for the actions of second and subsequent-tier suppliers?
According to the provisions of the new Tax Code, refusal of a VAT refund is possible exclusively if there are tax risks of the immediate suppliers, for whom the issuance of ESFs has been limited, who are involved in criminal cases under Articles 216 and 245 of the Criminal Code, and who have direct signs of reducing tax liabilities.
At the same time, within the framework of control, it is necessary to check all risks established during the audit.
Thus, according to paragraph 43 of the Rules for VAT Refund, the State Revenue Department generates a "Supplier Pyramid" report along the entire chain of the exporter's suppliers in order to identify suppliers for whom reductions in tax liabilities have been established as a result of tax evasion schemes, and for whom cross-audits must be conducted.