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Digital accounting: Stumbling blocks during a tax audit

Table of contents


At the beginning, the auditor determines whether the accounting has been fixed.

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

Common Errors: If there is a lack of recording of posting batches, there is a significant deficiency. If further significant deficiencies are identified, there is a risk of additional profit assessments.

To Do: As a rule, the firming up should be done on an ongoing basis. As soon as you receive the audit order, you should review it and catch up if necessary.

Consecutive invoice number

Due to the combination of sec. 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 examine these records”) and by using the auditor software IDEA, it is one of the easiest exercises for the auditor to find gaps in your sequential invoice numbers of your accounts receivable invoices.

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

To Do: Write down the invoice number assignment process and who has what access rights.

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

Note the first and last invoice of an invoice number range of the business year. If gaps occur, they should be clarified and noted along with the rationale.

At the latest when you receive the test request, you should check whether there are any gaps in the sequential numbering and clarify them if necessary.

Summary messages

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

Common errors: The values of the ZM do not match the entries in the revenue accounts.

The consequence is the denial of tax exemption.

To Do: Perform a reconciliation of the ZM with the revenue entries from the intra-Community deliveries. Also remember to check the VAT ID number!

If you notice any errors, make a correction immediately.

Retention of electronic data

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

Common mistakes: the electronic data can be changed afterwards or is not kept in the original, e.g. e-invoices are printed and filed in paper form.

In the case of storage deficiencies, there is a power of estimation according to the law. § 162 AO. By the way, this also applies in the event of a loss through no fault of your own!

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

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

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

Reminder on the tax retention periods

Accounting documents + commercial books: 10 years

Business letters: 6 years

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