Tax audit & procedural documentation in accordance with GoBD

This article helps you understand why account type and account category are playing an increasingly important role in tax audits, and how both must be correctly reflected in the procedural documentation. You will also learn what auditors actually look out for these days and what the tax authorities expect from digital accounting data.

Using clear examples and ‘if-then’ logic, you will learn how to avoid typical GoBD risks without making unnecessary changes to your systems. You will receive practical guidance on how data exports and documentation work together. This will enable you to prepare specifically for a tax audit and significantly reduce the number of queries or objections.

Digital bookkeeping has long been the norm, but as digitalisation advances, so too do the requirements imposed by the tax authorities. It is only when a tax audit takes place that it becomes clear whether companies have not only mastered their processes from a technical perspective, but have also documented them properly. A key document in this regard is the procedural documentation.

In recent years, there has been a noticeable shift in auditors’ focus: away from purely checking supporting documents, and towards the machine-readability of data. In this context, two terms are becoming increasingly important, although they have so far only been mentioned in passing in much of the procedural documentation: account category and account type.

But why has this information suddenly become so important? And what does this mean in practical terms for companies wishing to ensure their procedural documentation complies with GoBD?

Nowadays, in many cases, a modern tax audit no longer involves checking paper files. Instead, the tax authorities request digital accounting data – often as part of what is known as ‘Z3 access’ (data disclosure).

For this to work, simple journal entries are not enough. The auditor needs context – and this is precisely what account master data provides, in particular the account category and account type.

The GoBD (Principles for the Proper Maintenance and Retention of Books, Records and Documents in Electronic Form) form the legal framework for digital accounting and data access. It is particularly important that procedural documentation is complete, traceable, verifiable and up to date. The GoBD expressly require that a competent third party – including a tax auditor – must be able, within a reasonable period of time, to understand how data is generated, how it is processed and how it can be analysed. In this context, account type and account category are not merely technical details of secondary importance, but constitute crucial information for the tax classification of journal entries.

The account type describes the basic functional and tax classification of an account within the accounting system. It determines how entries in this account are treated for balance sheet and profit-and-loss purposes.

Typical account types are:

The account type is crucial for the tax audit because it determines:

Without a clear classification of the account type, an auditor cannot reliably categorise journal entries as expenses, income or balance sheet movements.

The account type describes the technical or functional role of an account within the accounting system. It is based more on system logic than on tax logic and supports the internal processing of journal entries.

Common account types include, amongst others:

The account type is relevant in the procedural documentation because it explains:

Account type and account category are not the same thing, but rather complement each other: the account type describes the tax implications, whilst the account category describes the system function.

The GoBD do not prescribe a specific data field labelled „account type“ or „account category“. Nevertheless, the tax authorities’ expectation is clear: the information required for tax assessment must be made available in a machine-readable format as part of the data submission. This means that information on account type and account category must be available, and may be provided either explicitly or implicitly. Explicit provision occurs when account type and account category are included as separate fields in the account master export and can be analysed directly by the auditor. In the case of implicit provision, the account type is derived, for example, from the chart of accounts used (such as SKR03 or SKR04), from the account number or from system-defined rules. However, this requires that this logic is unambiguous and documented in a traceable manner. This is precisely where procedural documentation comes into play.

In practice, GoBD compliance rarely fails because of the system itself, but rather because of the documentation. Whilst many procedural documents do state that data export is possible, it is not clear what data is included, how it should be interpreted, or what business logic underlies it.

For a tax audit to be successful, the procedural documentation must, amongst other things, address the following:

Many companies use standard charts of accounts. In such cases, the account type is often not explicitly recorded, but is derived from the structure of the chart of accounts. This is compliant with GoBD provided that the procedural documentation clearly describes this.

Example of clear documentation: Accounts are assigned to account categories and account types on the basis of the chart of accounts used (SKR03). The account category can be clearly derived from the account number. There is no provision for maintaining the account type separately within the system. As part of the data transfer, the complete account master data is provided, enabling the tax authorities to carry out an automated analysis. Without such an explanation, there is a risk of a lack of transparency for the auditors, with potentially unpleasant consequences.

When it comes to tax audits and procedural documentation, the same problems crop up time and again in practice:

These omissions do not necessarily result in formal deficiencies. However, they do increase the risk of enquiries, audit qualifications or even additional assessments.

The requirements regarding data access and analysability are not becoming any less stringent. On the contrary: the tax authorities are investing heavily in analytical tools – and expect data to be structured accordingly.

Well-maintained procedural documentation offers several advantages:

Account type and account category, in particular, are relatively straightforward to document accurately if you look at them carefully.

Account type and account category are not merely technical details, but key organisational elements of digital accounting. In modern tax audits, the tax authorities expect this information to be provided in a format that is machine-readable and professionally verifiable.

The GoBD do not prescribe a specific data field for this purpose, but they do require: transparency, traceability and comprehensive procedural documentation that discloses how the account type and account category are determined.

By incorporating these points into your procedural documentation, you can minimise the risks associated with tax audits, avoid the need for further enquiries and lay the foundations for future-proof, digital audit processes. It is therefore well worth ensuring clarity at an early stage – both within the system and in the documentation.

Find out more about digital process documentation with Opti.Tax now: