The Federal Ministry of Finance has issued the new principles governing the proper maintenance and retention of books, records and documents in electronic form, as well as data access – known as GoBD for short. The five most important rules for implementing the GoBD in practice are set out below.
The five key rules for implementing the GoBD
It is necessary to determine which systems are classified as primary and secondary systems
Upstream and ancillary systems form part of the data processing system (DPS) and must therefore be made available for the tax audit. These include, for example, till systems, merchandise management systems, and, in some cases, time-recording systems. Even MS Office products can be classified as front-end systems, for example, if invoices are created in MS Word, employees’ travel expenses are settled using an MS Excel tool, or provisions are calculated using MS Excel. But that is not all: upstream and ancillary systems must now also be audit-proof. The IT system used must guarantee that all programmes and data sets are audit-proof; in other words, the data must not be altered, or any alterations must be traceable. To this end, the purchase of a document management system will usually be essential.
No mix-up between paper and electronic receipts
A document created electronically must also be retained in digital form. It is not sufficient to print out an electronic document (e.g. a PDF invoice) and simply file away the paper copy.
Timely recording and posting are of particular importance
Business transactions must be recorded in a timely manner. The GoBD does not provide for any simplified rules regarding recording obligations for those who file quarterly returns or clients with turnover exempt from VAT. These taxpayers must therefore also ensure that their records are kept up to date.
Procedural documentation must be drawn up
Procedural documentation must be drawn up which sets out the content, structure, procedure and results of the data-processing procedure in a comprehensive and coherent manner. Businesses with cash registers must even have their cash management documentation to hand at all times from 1 January 2018.
Breaches will result in additional assessments
Glaring breaches of the GoBD may result in the entire set of accounts being rejected. At the very least, they will serve as leverage for the tax audit to enforce additional assessments in the range of 5 to 10 % of turnover.
The consequences of incorrect procedural documentation
The consequences of missing or incorrect Procedural documentation may vary. However, to avoid any discussions with a tax inspector arising in the first place, it is essential to take every step necessary to ensure that the relevant documentation is kept on file. It is therefore becoming increasingly important to draw up procedural documentation before an audit takes place. This is precisely why we have Opti.Tax.Doku and Opti.View developed. Opti.View supports regular checks of the accounts as part of an internal control system. The results of the macro-supported checks are transferred to Opti.Tax Doku via an interface and kept as an appendix to the procedural documentation.
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