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German tax audits, limitation period and self-disclosure

The audit order is an administrative act, and anyone who ignores a qualified request for cooperation pays for every full day. The first module walks through the external audit from the order to the audit report. The second covers unannounced spot checks and calculates the assessment period with its start-up and expiry suspensions. The third separates the correction under § 153 AO from the voluntary disclosure, with its blocking grounds and the payment under § 398a AO. Three modules with case studies worked on the statute itself.

Intermediate3 modules63 minModule 1 free to read

2026 rules — verified on September 23, 2026

Figures are tied to dated, sourced tax constants. A module whose rules have changed is flagged for review, and is unpublished automatically beyond 90 days.

By the end of this course, you can…

These outcomes are the modules' own: the promise cannot say anything the course does not teach.

  • recognise who is subject to a tax audit and how far its scope in the audit order may reach
  • use the rights around notification: moving the start date, audit focus areas, an objection against the order
  • prepare the duties of cooperation and the data access so that the audit does not stall on missing records
  • calculate the qualified request for cooperation and the delay penalty to the day
  • use the closing meeting and the audit report as the last opportunity to comment, and know their effect on later amendments
  • distinguish a VAT or wage tax spot check from an external audit and know what must be produced
  • determine the length of the assessment period by type of tax and degree of fault: one, four, five or ten years
  • set the start of the period correctly with the start-up suspension for returns
  • recognise when an audit, an objection or a disclosure suspends the expiry of the period, and where that suspension ends
  • derive from these rules until when a particular tax year stays open
  • recognise the duty to report and correct under § 153 AO and distinguish it from the voluntary disclosure under § 371 AO
  • assess whether an error, recklessness or intent is involved, and what depends on it for penalty, fine and deadline
  • determine the completeness requirements of a voluntary disclosure by type of tax and period
  • recognise the blocking grounds that make a voluntary disclosure come too late
  • calculate the tax, the interest on evaded tax and the payment under § 398a AO for a case above 25,000 €

The programme, module by module

Each module has its own page. Durations are derived from the actual text, never announced by hand.

What you take away

A handout you keep, not just a page you read. The sections are derived from the course itself: what is announced here is exactly what gets generated.

  • Participant handout (PDF)

    PDF

    • Learning objectives (3)
    • Key figures (8)
    • Mistakes to avoid (3)
    • Official sources (3)
  • Exercise workbook (Word)

    Word

    • Learning objectives (3)
    • Key figures (8)
    • Mistakes to avoid (3)
    • Official sources (3)

Answers live in a separate appendix: the participant handout and the workbook stay distributable before the exercise.

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Where this course leads

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Read in German

Educational content, current with the sources cited. It does not replace advice tailored to your situation. These courses are neither certifying nor CPF-eligible: they prepare for no certification registered with the French RNCP or specific register.