Germany’s New External Tax Audit Rules Enter Into Force

Germany’s new External Tax Audit Regulation (ApO) entered into force on September 10, 2026. It replaces the BpO 2000 and introduces updated rules on cooperation with tax authorities, audit planning, group audits and penalties for insufficient cooperation.

Germany’s new External Tax Audit Regulation (ApO) modernizes how tax audits are organized and conducted. It reflects changes introduced under the DAC7 Implementation Act and aims to make audits faster, more structured and more digital.

Taxpayers and authorities may now agree in advance on key audit arrangements, including timelines, deadlines, communication channels and audit priorities. The Regulation also clarifies qualified cooperation requests: if a taxpayer fails to provide requested information or documents, financial penalties may apply.

For large corporate groups, the rules strengthen coordination through lead group auditors. Coordinated payroll tax audits are also introduced for companies or groups with at least €50 million in annual turnover and 10,000 employees.

Impact on affected businesses

The new rules are particularly relevant for larger companies, corporate groups and businesses that may be subject to complex external tax audits. They can expect a more structured audit process, clearer timelines and stronger requirements to cooperate with the tax authorities.

Companies may also need to provide requested documents, explanations and data more quickly, especially where a qualified cooperation request is issued.

What should businesses do?

Affected businesses should review their internal tax audit procedures and make sure responsibilities are clearly assigned before an audit begins. They should also ensure that relevant tax records, supporting documents and digital data can be retrieved and provided without unnecessary delays.

Large groups should additionally review how communication between group entities and the lead auditor will be managed.

The reform is intended to make external tax audits faster, more coordinated and more efficient. For businesses, this means that good preparation, accessible documentation and timely cooperation will become even more important, while failures to respond properly to formal requests may result in additional compliance risks or penalties.

The main source for this article is the German External Tax Audit Regulation (ApO). Source

Ivana Picajkić, Medior Legal Consultant at Fiscal Solutions

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