GUHRSteuerberatung

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Service · Tax & Compliance

Back into compliance – discreet and protected.

Undeclared income, a wrong assessment, a looming audit: in moments like these, what counts is having someone stand calmly and securely between you and the tax office. From penalty-free voluntary disclosure (Selbstanzeige) to the tax court – we defend your position, in confidence.

  • Absolute discretion
  • Completeness above all
  • From disclosure to tax court
§371 AOPenalty exemption on a complete voluntary disclosure
1 monthAppeal deadline from assessment (§355 AO)

When it gets serious

When the tax office becomes the opponent.

In these situations you should not negotiate alone:

  • There is income that was never declared.

    A foreign account, crypto gains, an inheritance, hidden withdrawals: the thought of being discovered costs you sleep – and every day raises the risk.

  • The assessment is wrong – and the clock is ticking.

    An estimate, a disallowed business expense, a transposed figure. You have only one month to appeal a tax assessment (§355 AO). After that, it becomes final and binding.

  • The go-it-alone disclosure went wrong.

    A voluntary disclosure only works if it is complete. Anyone who forgets a single year or account loses the penalty exemption entirely – the lifeline turns into a confession.

  • The tax audit tips into criminal proceedings.

    What began as routine is heading toward tax criminal law. Now you need someone to take over the communication – not you, at the audit table.

  • The audit order is already in your mailbox.

    Once the audit order (Prüfungsanordnung) is served, a blocking ground under §371 AO applies. The window for a penalty-free disclosure is closing – now every day counts.

  • No one may find out.

    Bank, business partners, family: what you settle now must stay confidential. You need a contact who does not merely promise discretion, but lives it.

What we take on for you

Your defence – from disclosure to court.

Concretely, we act on your behalf:

  • Penalty-free voluntary disclosure (§371 AO)

    We reconstruct every non-time-barred year in full and quantify each position cleanly. Only a complete disclosure protects you – which is why completeness is non-negotiable for us.

  • Checking blocking grounds and timing

    We establish whether an audit order, discovery of the offence or opened proceedings have already triggered a blocking ground – and act while the window is still open.

  • Surcharge cases under §398a AO

    Where the evasion exceeds €25,000 per offence, a graduated surcharge (10 to 20%) replaces full exemption. We calculate it in advance so you know exactly what to expect.

  • Appeals against tax assessments (§347 AO)

    We file the appeal on time, argue it robustly and, where useful, apply for a suspension of enforcement (§361 AO) – so you do not have to pay while the matter is pending.

  • Proceedings before the tax court

    If the appeal fails, we litigate before the tax court (Finanzgericht) and, if necessary, up to the Federal Fiscal Court (Bundesfinanzhof). We run the case; you keep your back free.

  • Reaching agreement with the tax office

    Where the facts are unclear, we seek a factual agreement (tatsächliche Verständigung). All communication runs through us – you never deal with the tax office yourself.

What changes for you

From fear to being in control.

With the right support, the situation shifts:

  • Back into compliance.

    A clean, timely voluntary disclosure leads to exemption from prosecution. You close the chapter instead of suppressing it.

  • Calm instead of confrontation.

    From now on the firm speaks with the tax office – not you. You place a stressful dispute in experienced hands.

  • No excessive payment.

    We correct wrong or estimated assessments. You pay what is legally correct – not a euro more.

  • No enforcement pressure.

    With a suspension of enforcement we take the payment pressure out of the pending case – you can act without immediate collection.

  • Discretion that holds.

    The matter stays confidential. As tax advisors we are bound by statutory professional secrecy – that is the foundation of our work, not an add-on.

  • Clear numbers instead of nasty surprises.

    You know from the outset what to expect – back tax, interest and any surcharge. We work it out beforehand.

Karsten Guhr

A personal note from Karsten Guhr

People who come to us have often had sleepless nights. My first job is to take the pressure off and sort the situation out calmly. After that, one rule applies: a voluntary disclosure is done in full or not at all – only that way does it truly protect you.
Karsten GuhrManaging Director & Tax Advisor

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.
Clients in every federal state
BerlinHamburgCologneFrankfurtMunich

Head office Berlin · clients from Sylt to Garmisch

Nationwide · 100 % digital

One firm. Available anywhere in Germany.

Whether Berlin, Munich or somewhere in between: we run every mandate fully digital – DATEV-connected, signed PDFs, video meetings. No commuting, no postal delays, no 90s-style bookkeeping.

100 %digital, paperless, DATEV-connected
16/16federal states served
< 48 hresponse time, wherever you are
  • 01

    DATEV Unternehmen online

    Receipts, banking, payroll, reports – you work in the standard interface every German tax advisor speaks. No vendor lock-in.

  • 02

    Video meetings instead of on-site visits

    Quarterly review, tax strategy, holding check – via video with screen sharing. You save half a day every time.

  • 03

    Signed PDFs & digital powers of attorney

    Tax filings, annual accounts, contracts – signed via qualified e-signature. Accepted by the tax office, done in minutes.

How we work

Level-headed and in the right order.

Four steps – confidential from the very first contact:

Confidential intro call

You describe the situation, we listen – protected by our duty of professional secrecy. By the end, you know how serious it is and which routes are open.

01

Reconstruction & strategy

We reconstruct the relevant years in full, check blocking grounds and limitation periods, and set the strategy – disclosure, appeal, litigation or agreement.

02

Filing & representation

We file the disclosure or the appeal and take over all communication with the tax office and the court. You do not appear yourself.

03

Closure & safeguarding

We see the assessment and payment through to the end and then set up your tax affairs so the situation cannot repeat itself.

04

Frequently asked

What those affected want to know.

Answered in confidence and with substance:

The earlier, the more room to act.

Let's talk – in confidence.

Tell us about your situation in a protected intro call. We will tell you honestly how serious it is and which routes are open.