Since 2017, cash registers must also be digitally verifiable. The requirement for individual recording is set out in Section 146(1), sentences 1 and 2, of the German Fiscal Code. Entries and any other required records must be made individually, completely, accurately, in a timely manner and in an orderly fashion.
Procedural documentation required
Cash receipts and cash payments must be recorded on a daily basis if the taxpayer uses an electronic recording system. To ensure that the cash register data can be checked as part of a tax audit or cash register inspection (Section 146b of the German Fiscal Code (AO)), a Procedural documentation regarding the recording systems used. These should describe the operational procedures, the evaluation, programming and master data, and the details of any changes made to them. Manuals, operating instructions and programming guides must also be made available.
With our software Opti.Tax Documentation We offer guidance on drawing up procedural documentation. During an interview, the user is asked all the necessary questions, the answers to which result in complete and legally compliant procedural documentation. We advise and support our clients in the preparation of procedural documentation – drawing on the project experience we have gained over many years across a wide range of sectors.
Right of access to data during a cash register inspection
Cash register data is becoming a key focus of tax audits. Following the introduction of the requirement for individual transaction records, which came into force on 29 December 2016, tax inspectors have had the right to access data as part of unannounced cash register inspections since 1 January 2018.
In this context, access to the till system may be granted, either directly or indirectly, or the handover of a data storage medium may be requested. Normally, data is exported from the tills on a regular basis and stored on CD, DVD or a USB stick.
But what data does the tax inspector actually receive, and could they draw the wrong conclusions from it? A preliminary check of the till data is strongly recommended. If the inspector requests the data media, the structural information from the tills must also be exported.
Our testing software Opti.View helps to check the data prior to the audit. Furthermore, the description standard can be generated from the till data. We advise and support our clients in preparing for the tax audit.
Opti.List – the data archiving tool
Opti.List archives till data – there is no need to keep old till machines. From 1 January 2017, only electronic cash registers may be used.
From 1 January 2017, only electronic cash registers that enable the complete storage of all tax-relevant data may be used. This includes, in particular, journal data, analysis data, programming data and master data modification records (e.g. changes to item prices; user IDs). These requirements are set out in the Federal Finance Court (BFH) letter dated 16 December 2014, BStBl. II 2015, 519. In light of this Federal Ministry of Finance (BMF) circular, care must be taken to ensure that the above-mentioned information from the till system is stored and archived in digital form in its entirety and in an unalterable manner. The Karlsruhe Regional Finance Office recommends that, when switching to a new till system, the „old till“ should continue to be retained.
Opti.List is a data archive for tax-relevant data which no longer permits any subsequent alterations to the archived data. This enables tax-relevant data to be retained for 10 years. In the event of a tax audit or a cash register inspection under Section 146b of the German Fiscal Code (AO), time periods are specified for which an export in the IDEA description standard is to be carried out.
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