The provision of section 146 (2a) AO makes the relocation of an accounting system or other tax-relevant records abroad dependent on the consent of the German tax authorities. This is intended in particular to ensure data access by the German tax authorities to the tax-relevant data and IT systems of domestic companies. In addition, this also concerns the relocation of data storage, but may also affect accounting activities, for example, account allocation, entry into the accounting system or the scanning of receipts.
Accordingly, it is possible to keep electronic books and other records abroad upon application to the tax authorities. Without such permission, delay fines of up to €250,000 per year and company can be imposed under the Tax Code.
A number of conditions are required for this application. KPMG supports you in proving that the requirements have been met and in formulating and accompanying the application to the tax authorities.
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Christian Stender
Partner, Tax, CTO Tax; Head of Tax Innovation & Technology
KPMG AG Wirtschaftsprüfungsgesellschaft
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