Information on the taxpayer's main rights and obligations to cooperate during the external audit

The Federal Ministry of Finance (MoF) has updated its information on the taxpayer's main rights and obligations to cooperate during the external tax audit.

The German Tax Audit Regulations (BPO) outline the procedures and responsibilities for conducting audits by tax authorities in Germany. It includes general provisions, tasks of audit offices, and guidelines for external audits.

After discussion with the supreme tax authorities of the federal states the following instructions must be attached to the audit order (according to Section 196 Fiscal Code, which provides that tax authorities shall specify the scope of an external audit in an audit order that is issued in written or electronic form and that contains instructions on applicable legal remedies in accordance with Section 356).

In its circular, the BMF comments on the following points:

  • Start of the external audit
  • Procedure of the external audit
  • Findings of the external audit
  • Procedure of the external audit in the event of a suspected tax offense or tax infringement
  • Electronic communication as part of the external audit

Application

The current circular replaces the MoF circular from 24 October 2013 and applies from 1 January  2025.

Source:

Federal Ministry of Finance, circular of 17 February 2025 (IV D 3 - S 0403/00009/001/009).

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