1
Clarify the risk
Criminal-law, tax and commercial effects are reviewed separately and then brought together.
Input tax · Reverse charge · Cross-border supply chain
Limit SST and indirect tax risks cleanly
Indirect tax cases can escalate quickly because invoices, delivery evidence, payment routes and counterparty checks are interconnected. We review whether the tax authority is right to deny a claim or whether evidence can be supplemented and defended.
First key question
What deadline is running and which authority expects a response? The defense sequence is based on that.
Overview
What this engagement covers
Legal support for SST and indirect tax audits, input tax issues, reverse charge, cross-border supplies and carousel-fraud suspicions.
2
Secure documents
We define which receipts, accounts, invoices, contracts and emails are truly needed.
3
Keep a consistent line
Consistent communication avoids contradictions between the firm, tax advisers, management and the authority.
Input tax claim
An invoice is not the same as proof
For input tax and indirect tax claims, formal invoice requirements, supply evidence, business status and good-faith documentation matter. In supply chains, documentation must be especially robust.
- Review invoice features and supply descriptions.
- Document payment flow and supply evidence.
- Compile counterparty due diligence.
- Assess corrective invoices legally.
Cross-border trade
Cross-border supplies need reliable evidence trails
Transport evidence, customer information, tax registration details and filings must align. Contradictions often lead to questions or assessments.
Transport
Review CMRs, freight documents and collection cases separately.
Filings
Indirect tax returns, listings and accounting records must be consistent.
Partner review
Documented review can become decisive in a dispute.
Carousel-fraud suspicion
React early before the suspicion becomes fixed
Carousel allegations are not just about individual invoices; they involve what should have been known, market prices, payment routes and unusual business processes.
- Analyse supply-chain red flags.
- Secure internal approvals and communication.
- Rebut risk indicators.
- Review the criminal-law interface.
Risk matrix
Typical questions in the procedure
The table shows practical review points we capture in the first engagement phase.
| Review question | Significance | Required basis |
|---|---|---|
| Which invoices are affected? | Formal errors may be curable; substantive errors are not always curable. | Invoices, credit notes, contracts |
| How were goods or services evidenced? | Transport and supply evidence support the tax position. | CMR, delivery notes, emails |
| Were there red flags with the counterparty? | Good-faith arguments need documented checks. | Tax registration checks, onboarding documents |
FAQ
Frequently asked questions about limiting SST and indirect tax risks
Can an incorrect invoice be corrected?
In many cases, yes. The decisive points are error type, timing and evidence of the actual supply.
What does reverse charge mean?
Tax liability can shift to the recipient of the supply. Errors often lead to additional assessments or formal corrections.
When does indirect tax become criminally relevant?
When the authority assumes intentional false statements or conscious involvement in a fraudulent supply chain.