Digital accounting: pitfalls during a tax audit

Table of contents


At the beginning, the auditor determines whether the bookkeeping has been recorded.

Basis: Gem. GoBD, you must record your bookkeeping on a monthly basis, at the latest by the 30th of the following month. This is intended to ensure immutability.

Frequent errors: If posting batches are not recorded, there is a significant error. If further significant deficiencies are identified, there is a risk of additional profit assessments.

To Do: As a general rule, the recording should take place on an ongoing basis. As soon as you receive the examination order, you should check it and make up for it if necessary.

Consecutive invoice number

Through the combination of § 147 para. 2 AO (which states that the tax authorities have the right to “inspect the stored data and use the data processing system to check these documents”) and by using the IDEA auditor software, it is one of the easiest exercises for the tax auditor to find gaps in your consecutive invoice numbers of your accounts receivable invoices.

Common errors: Depending on the invoicing program or when switching to other programs, there may be gaps in the assignment of invoice numbers. If these gaps cannot be clarified and checked for plausibility, this usually leads to estimates of sales.

To Do: Write down the procedure for assigning invoice numbers and who has which access rights.

Check the possibilities of a digital export of the invoice overview from your invoicing program.

Make a note of the first and last invoice of an invoice number range of the financial year. If there are any gaps, these should be clarified and noted together with the reasons.

You should check whether there are any gaps in the consecutive numbering at the latest when you receive the audit request and clarify these if necessary.

Summarized messages

If you carry out certain cross-border deliveries/other services within the EU, you must submit a recapitulative statement in accordance with Art. § 18a UStG, because with the implementation of the Quick Fixes, the ZM became a substantive legal requirement for tax exemption.

Frequent errors: The values of the ZM do not match the postings to the revenue accounts.

The consequence is the denial of tax exemption.

To Do: Carry out a reconciliation of the VAT returns with the revenue postings from the intra-Community deliveries. Also remember to check the VAT ID number!

If you notice any errors, make a correction immediately.

Storage of electronic data

All commercial and business letters and accounting documents must be stored in the format in which they were received. Gem. RZ 135 GoBD, documents subject to retention requirements can be converted into their own formats. The prerequisite for this is, however, that no changes are made to the content or images and that data access by the tax authorities and machine readability are not restricted.

Common errors: The electronic data can be subsequently changed or the original is not stored, e.g. e-invoices are printed and filed in paper form.

In the event of storage deficiencies, there is the right to make an estimate in accordance with. § 162 AO. Incidentally, this also applies in the event of loss through no fault of your own!

To Do: Constantly check whether your software guarantees the immutability of the data. It must be possible to view e-invoices in a readable format.

Note: If you back up the electronic data in a cloud, clarify where the server is physically located. Gem. 146 para. 2b AO, an application must be submitted to the tax authorities if the server is located in a third country.

It is important to ensure that the electronic data is stored securely for the entire retention period.

Reminder on the tax retention periods

Accounting documents + trading books: 10 years

Business letters: 6 years

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