Digital tax audit

Tax authorities are only allowed to request access to tax-relevant data. So it’s important to identify and separate this data in advance. If you don’t draw a clear line, there’s a real risk that data protected under the General Data Protection Regulation (GDPR) or the German Federal Data Protection Act (BDSG), or data that auditors shouldn’t see, is used as part of the audit. Taking a structured approach to separating tax-relevant data from protected data helps you stay compliant and reduces that risk.

Strong data quality is a basic requirement for GoBD-compliant processes. At PwC, we carry out GoBD readiness checks, health checks, and gap analyses to give you a clear view of weaknesses in your processes, systems, and documentation. This helps you strengthen traceability, reduce tax risk, and be ready for audits.

You must keep tax-relevant data electronically accessible for analysis for six or ten years, as applicable. This applies even when you decommission systems, migrate data, or transition to S/4HANA. We work with you to identify a practical, long-term retention solution and make sure the data remains accessible for analysis to the extent required by law.

The tax authorities may request access to your system and process documentation. GoBD-compliant process documentation, including a clear description of your data processing procedures and your internal control system (ICS), is therefore essential. With PwC’s support, you document your systems and procedures in a structured, efficient way so you can meet your obligations under German commercial and tax law and demonstrate control during audits.

The tax authorities may use all three types of data access together. At PwC, we help you set up access via Z1, Z2, and Z3 for all tax-relevant systems, increasingly also via interfaces in line with Section 147b of the German Fiscal Code (AO). Clear access and authorisation concepts limit this access to tax-relevant data for the audit period while still letting you meet your legal obligations.

At PwC, we use our GoBD readiness check to give you an objective view of how prepared you are. We carry out detailed analyses and set out clear recommendations that help you refine your strategy, tackle weaknesses in your processes and IT systems, and reduce risks.

Based on your IT systems, our specialists assess how you can provide the required types of data access and interface formats. This helps you meet the technical requirements for data exports so you can comply with the relevant rules and respond confidently to a tax audit.

Our specialists review your exported data for completeness. We use IDEA data analysis software, which the tax authorities also use. This helps you avoid lengthy follow-up questions or technical problems and speeds up the audit process.

Working closely with you, we carry out standard tax analyses and cross-topic analyses. Our detailed data review helps you understand what a tax audit may uncover, assess the possible impact, and reduce the risk of unexpected findings.