The provision in Section 146 (2a) AO makes the relocation of an accounting system or other tax-relevant records abroad dependent on the approval of the German tax authorities. This is intended in particular to ensure that the German tax authorities have access to the tax-relevant data and IT systems of domestic companies. In addition, this also concerns the transfer of data storage, but can also affect accounting activities, for example account assignment, entry into the accounting system or the scanning of documents.

It is therefore possible to apply to the tax authorities to store electronic books and other records abroad. Without such authorisation, fines of up to €250,000 per year and company can be imposed in accordance with the German Fiscal Code.

A number of conditions are required for this application. KPMG supports you in proving that you fulfil the requirements and in formulating and accompanying the application to the tax authorities.