Critical change from the Tax Inspection Board: The “I did not know it was a fake invoice” defence is no longer valid
As of 1 October 2025, taxpayers who use fake or misleading invoices can no longer rely on the argument that they were unaware. Companies are expected to redesign their supplier due diligence and document controls.
The Tax Inspection Board is tightening its approach against fake or misleading invoices. Under the new practice, the simple claim of “I did not know” will no longer be seen as sufficient defence; instead, auditors will look at whether the taxpayer exercised a reasonable level of control over its suppliers and documents.
Businesses that fail to run basic background checks on high‑risk suppliers – such as tax office registration, filing history or unusual turnover patterns – may face heavy assessments even if they did not intentionally participate in fraud. This is particularly relevant for recently incorporated entities issuing large volumes of invoices in a short period of time.
If a company receives a risk alert about one of its suppliers, it is expected to review past transactions, reconsider the commercial relationship and document its evaluation. Contract files, delivery notes, transportation records and proof of payment become essential pieces of evidence in such reviews.
Many organisations are therefore updating their internal control frameworks, adding mandatory tax checks and red‑flag criteria to supplier onboarding procedures. In the long run, having a written vendor risk policy agreed with the accountant will be one of the strongest safeguards during inspections.
In short, the new regime shifts the responsibility towards proactive risk management rather than passive defence. Companies that invest in systematic controls today will be better positioned against both financial penalties and reputational damage tomorrow.
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