GUHRSteuerberatung

Sparringspartner für Unternehmer.

Service · Compliance & risk

Tax audit, voluntary disclosure, appeal.

A GmbH above €1M revenue is audited regularly – the question is not whether but how much it costs. We prepare you, defend you during the audit, secure binding rulings under §89 AO and use voluntary disclosure under §371 AO to protect reputation and freedom.

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  • Estimation powers challenged
  • Suspension of enforcement filed
  • Voluntary disclosure on time
€30k+typical swing through professional audit negotiation
7Structures in this area

Structuring catalogue

What we actually build for you.

Every card represents a real structure we implement for comparable mandates. Green is the upside, red is the pitfall – so you see where the lever sits and what we need to safeguard.

P07Demanding

Tax-audit preparation

For whom: All GmbHs with revenue ≥ €1M

Upside

Avoid five-figure back-tax through proactivity

Pitfalls
  • GmbHs above €1M revenue are audited regularly
  • Documentation gaps are costly
  • Run a hidden-distribution check first
P123Demanding

Tax-audit strategy & defence

For whom: Directors in an active audit

Upside

€30k+ swing through professional negotiation

Pitfalls
  • Don't accept estimation powers without challenge
  • File an appeal in parallel
  • Risk of worse outcome (§367 AO)
P122Demanding

Binding ruling (§89 AO) – the shield

For whom: Directors planning a structure

Upside

Legal certainty before execution – no audit risk afterwards

Pitfalls
  • Fee scales with the disputed amount
  • Office may refuse if facts are unclear
  • No retroactive effect
P124Highly complex

Voluntary disclosure (§371 AO)

For whom: Directors with legacy issues

Upside

Immunity from prosecution upon full disclosure

Pitfalls
  • Audit notification blocks the relief
  • Incomplete disclosure = no relief
  • 5% surcharge
P39Highly complex

Voluntary disclosure – execution

For whom: Clients needing to amend filings

Upside

Immunity protects the company and its reputation

Pitfalls
  • All tax types and all open years
  • Back-tax + 6% interest + surcharge
  • Tight timing
P70Demanding

Appeal & tax-court procedure

For whom: Directors facing contested assessments

Upside

Assessments are challengeable – mind the worse-outcome risk

Pitfalls
  • One-month deadline
  • Worse-outcome risk under §367 (2) AO
  • Suspension of enforcement must be filed separately
P114Established

Implementing the e-invoicing duty 2025/2026

For whom: All B2B GmbHs

Upside

Avoid fines and audit exposure from non-compliance

Pitfalls
  • Transition period running
  • XRechnung / ZUGFeRD formats
  • Archiving duty
Which of these fits your situation?In a 30-minute strategy call we map your situation onto the catalogue and name the two or three structures with the biggest effect for you.
Book the strategy callFees & terms→030 555 721 370