For companies, in the era of SAF-T, e-Invoicing and automatic data cross-checking: managing tax risk, defending the deductibility and the economic substance of transactions, in audits and in litigation. Available internationally.
SAF-T, e-Invoicing, e-VAT, e-Transport — in a few years, the authority has moved from paper audits to digital surveillance that automatically cross-checks the reported data. A discrepancy between VAT returns, e-Invoice and SAF-T no longer goes unnoticed: it triggers a notice or an audit.
In parallel, the focus of the audit has shifted from form to substance. It is no longer enough that an invoice exists: the authority checks the economic substance of the transaction — whether the service was actually provided, whether it had a real economic justification, whether the documentation supporting it exists. The absence of this documentation has become the main reason for refusing deductibility, both for VAT and for corporate income tax.
For a company, this means that tax risk has shifted: it is no longer only about declaring and paying correctly, but about being able to prove, at any time, the reality and the economic rationale of every significant operation. And the consequences of a failed audit do not stop at the company — they increasingly reach the personal assets of the director.
Based on recent audit practice and the risks flagged by the authority, these are the areas that generate the most adjustments.
Expenses for management, consultancy or intra-group services, refused for deduction for lack of evidence of actual provision: contracts, reports, deliverables, justification of economic necessity.
Refusal of deduction on transactions deemed to lack substance, with suppliers having tax problems, or insufficiently documented — still the most frequent source of additional obligations.
Company expenses used for the personal benefit of shareholders — property, vehicles, purchases without economic rationale — reconsidered by the authority as dividend distributions, with tax and ancillary charges.
Sums withdrawn as a "loan" without real documentation and without repayment capacity can be reclassified as disguised dividends, with tax, penalties and director liability.
Differences between SAF-T, VAT returns, recapitulative and informative statements, e-Invoice and e-Transport, detected automatically and turned into grounds for verification.
Classifying the company in a risk category with concrete consequences: limits on VAT refunds, audits triggered as a priority, heightened attention to every operation.
This page does not deal with ongoing prevention (covered by advice) or with challenging a decision already issued (covered by litigation), but with understanding and managing these specific risks when the company is exposed.
Identifying, before an audit, the areas where economic substance or documentation are vulnerable — and reinforcing them while there is still time.
Building and presenting the file that proves the reality and economic rationale of the contested transactions, during the tax audit.
The analysis and documentation of loans and operations between the company and shareholders or group companies, to prevent reclassification as disguised dividends.
Assessing the risk that a company problem turns into personal liability — dealt with in detail on the dedicated page.
Because the invoice alone is no longer enough. The audit checks economic substance: whether the service was actually provided, whether it had an economic justification for the company and whether the documentation proving it exists — contracts, reports, deliverables, correspondence, work records.
Expenses for management, consultancy or intra-group services are the most exposed. An invoice without a file demonstrating the actual provision is, today, a risk, not a protection.
It is the reclassification by the authority of sums or benefits received by shareholders as dividend distributions, even if they were recorded otherwise — as a loan, as a company expense or as a payment.
Frequent examples: loans granted to shareholders without real documentation and without repayment, company expenses on goods used personally (property, vehicles), payments without economic rationale. The consequence is dividend tax, plus penalties, and sometimes director liability.
They have become a sensitive area. Using a loan as an alternative to dividends is viewed with suspicion, especially when real documentation, a market interest rate or repayment capacity are missing, or when it affects the company's capitalisation.
It does not mean the loan is prohibited — it means it must be structured and documented rigorously, at market price, to withstand a possible audit. A prior analysis of the current structure can prevent a costly reclassification.
Classification in the risk category has concrete effects: it can lead to limits on VAT refunds, can trigger audits as a priority and prompts heightened attention from the authority to the company's operations.
The risk criteria have changed and are updated periodically. An assessment of the company's position against these criteria and a risk-reduction strategy are useful especially for firms with frequent VAT refunds.
A tax audit generally takes place within the limitation period of the right to establish tax obligations. In practice, an audit in 2026 can cover several previous years. This is why documentation must be kept and maintained in a form that withstands a verification years later.
Whether it is an ongoing audit, a transaction with related parties or an expense you anticipate will be challenged, a conversation clarifies the real risk and what can be reinforced in the defence.