1
Clarify the risk
Criminal-law, tax and commercial effects are reviewed separately and then brought together.
Field audit · Estimates · Closing discussion
Defend a tax audit in a structured way
A tax audit is not just an accounting check. Individual findings can lead to additional taxes, interest, amended assessments and, in critical cases, criminal-law indicators. We support the audit strategically, document disputed points and negotiate on a reliable basis.
First key question
What deadline is running and which authority expects a response? The defense sequence is based on that.
Overview
What this engagement covers
Support in tax audits, field audits, closing discussions, estimates, appeals and interfaces with tax criminal defense.
2
Secure documents
We define which receipts, accounts, invoices, contracts and emails are truly needed.
3
Keep a consistent line
Consistent communication avoids contradictions between the firm, tax advisers, management and the authority.
Preparation
The audit begins before the first appointment
The audit notice shows tax types, years and often initial focus areas. From this, it is possible to determine which documents should be prepared and which risks should be discussed internally in advance.
- Review the audit notice and secure deadlines.
- Review accounting, cash records and contracts.
- Set communication rules for employees.
- Define risk areas and negotiation goals.
Estimate
Estimates require points of challenge and counter-calculation
Estimates often arise from formal deficiencies. The key issue is whether the method, plausibility and amount can be challenged or limited by your own calculations.
Cash records
Formal errors must be separated from actual income.
Benchmark comparison
Comparative values are not automatically proof of specific additional revenue.
Documentation
Traceable documents significantly improve the negotiation position.
Conclusion
Use the closing discussion as a negotiation window
Before the closing discussion, all disputed points, evidence, legal arguments and financial effects should be prepared.
- Formulate agenda and counterarguments.
- Coordinate figures with tax advisers.
- Review criminal referral risk.
- Prepare appeal options.
Risk matrix
Typical questions in the procedure
The table shows practical review points we capture in the first engagement phase.
| Review question | Significance | Required basis |
|---|---|---|
| Which years and tax types is the authority reviewing? | The scope limits file requests and deadlines. | Audit notice |
| Are there formal bookkeeping deficiencies? | They can form the basis for estimates. | Cash reports, process documentation |
| Is there a risk of criminal referral? | Certain findings can be referred to tax enforcement authorities. | Auditor notes, interim reports |
FAQ
Frequently asked questions about structured tax audit defense
Should I give the auditor all documents immediately?
Only in a structured way. Unreviewed data packages can open new questions. An organised handover based on audit requests is sensible.
Can a tax audit be postponed?
For certain reasons, a postponement can be requested. It should be factually justified and submitted on time.
What happens after the closing discussion?
An audit report and amended assessments follow. Appeals can be filed against assessments if needed.