Start of an external audit by requesting documents

The request for documents by the tax auditor is an audit action that can lead to a suspension of the limitation period for assessment.

If the tax office begins an external audit before the assessment period has expired or if the start of the audit is postponed at the taxpayer's request, this suspends the expiry of the assessment period. The tax office has not yet started an external audit when the auditor appears and hands over the audit order, but only when the auditor takes action to investigate the tax case after handing over or sending the audit order. The Düsseldorf Fiscal Court has ruled that the request for documents by the tax auditor also constitutes an audit action that leads to a suspension of the assessment period. It is not necessary for the auditor to request documents relating to a specific individual matter or to ask questions. The request for comprehensive documents realizes the purpose of the tax audit, which is to examine the tax situation as a whole.