German Tax Proceedings & Finanzamt
German tax procedure and representation before the Finanzamt
Review of German tax assessments, responses to enquiries from the Finanzamt and assistance with objections, amendment procedures, tax audits and corrections of prior tax filings.
German Tax Procedure
Address tax issues before procedural deadlines expire
A German tax procedure often starts with a tax assessment, an enquiry, a request for supporting documents or the announcement of a tax audit. The first step is to determine what the Finanzamt is requesting, the current procedural status and the relevant deadlines.
Reviewing the underlying tax calculation is only part of the analysis. It is equally important to determine which procedural options remain available, such as an objection, amendment request, correction, suspension of enforcement or another adjustment mechanism under the German Fiscal Code.
We review tax assessments and correspondence, prepare responses and legal remedies and handle communication with the German tax authorities.
Scope of services
Assistance at the main stages of German tax proceedings
From reviewing a tax assessment to supporting a tax audit, we combine substantive German tax analysis with the appropriate procedural response.
01
Review of tax assessments
We compare the tax assessment with the filed tax return and review differences, calculations, explanations and potential procedural remedies.
- Income tax assessments
- Corporate income tax assessments
- Trade tax assessments
- VAT assessments
- Separate tax determinations
- Review of procedural status
02
Objection proceedings
Where a tax assessment is incorrect or a different legal position should be taken, we review, prepare and substantiate an objection with the German Finanzamt.
- Review of the objection deadline
- Filing the objection
- Applications and legal reasoning
- Evidence and supporting documents
- Communication with the Finanzamt
- Review of the objection decision
03
Suspension of enforcement
Filing an objection does not generally suspend the obligation to pay the assessed tax. Where the legal requirements are met, we therefore review an application for suspension of enforcement.
- Review of legal requirements
- Application to the Finanzamt
- Substantiation of serious doubts
- Partial suspension
- Coordination with the objection
04
Finanzamt enquiries
We respond to requests for information and supporting documents and present the relevant facts and tax analysis in a structured form.
- Requests for supporting documents
- Questionnaires from the tax authority
- Statements of facts
- Tax position papers
- Extension requests
- Tax-authority correspondence
05
Estimated tax assessments
Where the Finanzamt has estimated the tax base, we review how the actual figures can be submitted and the assessment corrected.
- Estimation under Section 162 AO
- Unfiled tax returns
- Submission of actual figures
- Objection against estimated assessments
- Suspension of enforcement
06
Amendment and correction procedures
Even after the normal objection deadline has expired, a German tax assessment can still be amended in certain circumstances. We review the applicable correction rules.
- Obvious errors
- Assessments subject to review
- Provisional tax assessments
- Amendment provisions under the AO
- New facts or evidence
- Consequential and basic assessments
07
Correction of prior tax returns
If errors or incomplete information are identified in tax returns already filed, we review the required German tax corrections.
- Incorrect tax returns
- Previously unreported income
- Foreign income
- Investments and company interests
- Multiple tax years
- Structured correction of prior filings
08
Tax audits
We support businesses and entrepreneurs during German tax audits, from the audit notice through review of the final findings.
- Audit notices
- Document requests
- Communication with the auditor
- Audit findings
- Closing meeting
- Amended tax assessments
09
Special VAT audits
In German VAT audits, we assist with reconciling bookkeeping, invoices and VAT filings and respond to the tax authority's questions.
- VAT advance returns
- Input VAT
- Invoice review
- Intra-Community transactions
- Reverse charge
- Annual VAT returns
10
Liability and other tax notices
In addition to ordinary tax assessments, liability notices, separate determinations and other administrative acts can create significant German tax exposure.
- Liability notices
- Separate determination notices
- Late-filing penalties
- Interest assessments
- Late-payment surcharges
- Review of available remedies
Objections against tax assessments
Review the assessment first – then respond strategically
Not every difference in a German tax assessment requires an extensive objection procedure. The first step is to identify why the Finanzamt departed from the tax return and whether the adjustment is actually incorrect.
Where correction is required, an objection can be filed and supported by a structured presentation of the facts, legal analysis and appropriate supporting documents.
At the same time, it should be determined whether the disputed amount remains payable during the objection procedure or whether an additional application for suspension of enforcement should be made.
Finality and amendments
An amendment may still be possible after the objection deadline
Expiration of the regular objection deadline does not necessarily mean that a German tax assessment can never be changed. The German Fiscal Code contains a number of correction provisions.
Which provision applies depends on the specific facts. Relevant issues can include an assessment subject to review, provisional assessment, obvious errors, new facts or evidence, or changes to a basic assessment.
Before requesting a correction, the procedural status of the assessment and the available statutory amendment route should therefore be reviewed.
Typical situations
When assistance with German tax procedure is useful
The Finanzamt treats income, deductions, business expenses, losses or foreign tax credits differently from the filed return.
A tax return was not filed on time and the Finanzamt estimated the taxable income or other tax base.
The Finanzamt raises questions regarding foreign bank accounts, investments, real estate, company interests or tax treaties.
Questions concern business expenses, managing-director compensation, distributions, tax losses, company interests or hidden profit distributions.
VAT filings, input VAT, invoices or international transactions are reviewed or treated differently by the German tax authorities.
A German tax procedure must be coordinated with tax returns, supporting documents or tax-authority matters in the United States, Switzerland or another country.
German Tax Authorities
Representation before the German Finanzamt
We handle tax-related communication with the Finanzamt, organize facts and supporting documents and represent the taxpayer's position during German administrative tax proceedings.
Assessments, foreign income, investments, rental property, company interests and personal tax matters.
Corporate income tax, trade tax, separate determinations, year-end tax issues and shareholder matters.
VAT advance returns, annual returns, input VAT, reverse charge and cross-border transactions.
German tax audits
Structured support during a tax audit
During a German tax audit, the tax authorities may review several tax types and multiple assessment periods. Structured preparation helps ensure that requested information is supplied efficiently and potential tax issues are identified at an early stage.
We review the audit notice, assist with communication with the tax authorities and prepare tax-related facts and supporting documents for the audit.
After the audit, we review the findings, potential additional tax exposure and any amended assessments issued as a result. Where necessary, subsequent legal remedies can be considered.
How we work
From a Finanzamt letter to the final decision
Assessment and deadlines
We review the Finanzamt correspondence, procedural status, prior tax returns and relevant deadlines.
Tax analysis
We analyze the substantive tax issue, calculations, available evidence and potential procedural routes.
Response or legal remedy
We prepare the required submission, including applications, legal reasoning and supporting documentation.
Representation and completion
We handle further enquiries and review the amended assessment or final administrative decision.
Related Services
German tax proceedings and tax compliance
Procedural issues frequently arise in connection with individual income tax, business tax, VAT and cross-border tax matters.
Frequently asked questions
German tax proceedings and objections
Do you review German tax assessments that have already been issued?
How long do I have to object to a German tax assessment?
Do I still have to pay the tax if I file an objection?
What can I do about an estimated tax assessment?
Can a German tax assessment still be changed after the objection deadline?
Do you assist with German tax audits?
Do you represent clients in cross-border tax proceedings?
Contact
Let us discuss your German tax proceeding.
If possible, send us the relevant German tax assessment or Finanzamt letter together with the affected tax return and supporting documents. During the initial consultation, we review deadlines, required action and the expected scope of services.
