Supplier due diligence can feel inconvenient when a quote solves this quarter’s margin problem. The sample works, stock is available and an invoice is ready. The question that gets dropped is often the simplest: what makes this price possible?
Clearance stock, different warranties or payment terms may explain it. An unexplained discount deserves questions, not an accusation. Before committing funds, the buyer needs a record connecting the goods, the contracting party and the payment instructions.
What to check first
Establish the facts needed for the decision, then identify the missing records.
- Real goods do not validate every party in a trade.
- A discount is a question to investigate, not proof of wrongdoing.
- Reconcile the seller, invoice issuer, payee and shipping party.
- Obtain qualified advice on the relevant tax treatment.
- Keep the questions and answers that informed the payment decision.
1. News observation: the transaction matters as much as the goods
On 17 September 2026, the EPPO announced an investigation into alleged misuse of VAT margin treatment for new mobile phones, with estimated tax losses exceeding EUR 15.7 million. Those concerned remain presumed innocent.
The following buyer-side analysis is our own, not an account of unpublished case facts. Product authenticity and transaction reliability are separate questions. A buyer can receive a genuine item while still lacking an explanation of who sold it, invoiced it or received the money.
2. What should a buyer ask about an unusually low quote?
Compare like with like: condition, warranty territory, returns, delivery costs, tax responsibilities and payment timing. A unit price alone hides these differences. Ask for a written explanation of the gap that remains after the commercial terms are aligned.
A supplier need not disclose every trade secret to explain what it is selling and who is responsible. Refusal to confirm basic conditions is a reason to limit exposure, request evidence or seek advice before paying. It is not a reason to label the business fraudulent.
3. Five records to reconcile in supplier due diligence
01
Goods
Match models, batches and lawfully available serial-number records to orders and receipts.
02
Parties
Explain relationships between the seller, invoice issuer, payee and shipping party.
03
Tax explanation
Record the stated treatment and refer it to qualified advisers where needed.
04
Delivery
Compare dates, quantities and handovers rather than relying on one delivery note.
05
Exceptions
Record who approved account changes or other departures from the agreed terms.
4. An invoice is evidence, not a safety certificate
Check registration and authority independently, then connect the invoice to the order, payment and delivery record. Record when each check occurred. A company’s present position may differ from its position when the contract was signed.
Specific tax obligations and recovery or deduction rights need advice in the relevant jurisdiction. A risk report can organise facts and gaps; it cannot promise that a transaction will survive every tax or legal challenge.
5. What if the money has already been paid?
Preserve conflicting versions instead of tidying them into a consistent story. Keep originals, create controlled working copies and distinguish verified facts from explanations supplied by the counterparty. A discrepancy may later be important evidence.
Procurement, finance and counsel should then agree the response. Requesting documents, limiting further exposure or reviewing contractual remedies may be appropriate. Do not stop every payment or circulate allegations solely because a similar business appeared in the news.
6. Where Relieved Group can assist
Within an agreed scope, we can research public company and dispute records, map transaction relationships and organise payment and delivery timelines. The output should show what was verified, what remains unknown and what counsel or tax advisers need to assess.
We do not obtain private banking or account data without lawful authority. Access to cross-border records varies. Research cannot guarantee a finding of criminality, tax clearance or recovery.
7. A final reminder: document the reason for the discount
Add one question to the purchase approval: which records support this price difference? A long relationship or a confident sales pitch may matter commercially. Neither replaces an answer about this shipment and this payment.
Frequently asked questions
Does a low price prove supplier fraud?
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No. Stock clearance, warranty differences, delivery commitments and payment terms can explain a discount. Compare the full terms before treating the price as unusual. Ask for evidence supporting any remaining gap, then cross-check the parties, goods and delivery records. Record uncertainty without turning it into an allegation. The appropriate response depends on the evidence and the exposure of the particular transaction.
Why check a registered company with valid invoices?
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Registration confirms some facts about an entity; it does not establish the origin of every product or the legitimacy of every payment. An invoice also has a limited role. Due diligence connects these records to the actual transaction, identifies who performs each obligation and records unresolved differences. A buyer should understand which company is responsible if goods, warranties or payment instructions later become disputed.
Can we refuse payment when the payee is a different company?
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A different payee warrants verification, but there may be a documented collection or group settlement arrangement. Preserve the original and revised instructions and independently check the authority for the change. Counsel should assess any contractual right to withhold payment or pause performance. A risk review supplies facts for that decision; it does not replace legal advice about the consequences of non-payment.
What should we preserve after payment?
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Keep quotations, orders, invoices, delivery records, bank confirmations and complete correspondence with attachments. Record where each item came from and when it was obtained. Separate originals from working copies and restrict access. Do not retrospectively change dates or ask a supplier to produce a cleaner version that conceals discrepancies. Counsel and authorised reviewers can then assess the evidence without losing its original context.
Can a risk consultant confirm the VAT treatment?
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A consultant can identify the claimed treatment and organise relevant transaction facts. Whether a particular tax regime applies, and what a buyer must report or may deduct, requires qualified advice in the relevant jurisdiction. The report should state its source limitations and unresolved questions. It should not be presented as a tax opinion or a guarantee against a later inquiry.
Can we commission a limited review before any loss occurs?
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Yes. A review can focus on one supplier, payment instruction or unexplained commercial term. Start with basic entity details, a draft contract and the precise decision you need to make. There is no need to send an entire customer database at first contact. Agree the permitted sources, confidentiality arrangements, cost and expected deliverables before substantive work begins.
Sources
