by the German tax authorities. A tax audit allows the authorities to examine the tax-relevant factual and legal circumstances of a business and to verify whether its tax obligations have been correctly fulfilled.
Under the German Fiscal Code external tax audits are permitted in particular for taxpayers carrying on a trade or business, agricultural or forestry operations or a professional activity.
The precise scope of the audit depends on the audit order and the individual business concerned. Tax audits can involve the examination of accounting records and other documents relevant to the determination of taxes.
For companies with international operations, the audit may also raise questions requiring an understanding of both the underlying commercial transactions and their tax treatment.
The German framework for external audits has recently undergone procedural changes. In September 2026, the Federal Ministry of Finance published a new legal framework. According to the Ministry, the reforms include measures aimed in particular at accelerating external tax audits.
A German external tax audit is conducted by the competent tax authorities within the legal framework. The scope of the examination is formally determined and the taxpayer is required to cooperate with the audit.
In practical terms, an audit may involve reviewing accounting documentation, tax-relevant records and individual transactions. Digital records can also be relevant: the Federal Ministry of Finance expressly identifies data access and the auditability of digital documents as part of the regulatory framework for tax audits.
Issues identified during an audit can result in discussions between the taxpayer, its advisers and the tax authorities and may ultimately affect the relevant tax assessments.
For international businesses, having the underlying transactions and documentation explained consistently can be particularly important where the auditor is examining cross-border structures or transactions.
We advise and represent German and international businesses in connection with tax audits in Germany.
Our assistance may begin as soon as an audit is announced. We can review the scope of the audit, identify legally relevant issues and assist in preparing the business for communications with the tax authorities.
During the audit, we can handle legal questions, prepare submissions and communicate with the competent authorities. Where individual findings are disputed, we can analyse the legal position and present the taxpayer’s arguments in a structured manner.
We can also assist following the audit where its findings lead to amended tax assessments or further proceedings. For businesses with cross-border activities, our international structure enables us to coordinate German tax-law issues with the underlying corporate and commercial arrangements in other jurisdictions.
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