Summary risk assessment
The summary risk assessment ( SRP ) is a systematic, template-supported (largely automated), interactive audit network and is used in tax audits for risk assessment and strategic alignment, for individual audit field selection and for the detection of manipulations . In almost all federal states, the federal examination, parts of the customs and the Dutch tax authorities. a. the SRP concept, with its focus on "understanding of methods including validation" and "systematic networking of various audit approaches for meaningful decision-making bases", used as an introduction to complex digital testing technology; Initial experiences with the increasingly widespread business intelligence programs have shown that a better understanding of the working method can be observed on the basis of the SRP.
In particular, the SRP can be used to examine extensive tax data. The SRP serves the tax audit for the quick assessment of the need for an intensive review of taxation data ( risk management ), the definition and limitation of audit areas and the complete evidence in the case of deficiencies in the area of the complete recording of income including an additional estimate based on the available operating data; Due to the internal (multi-perspective and interactive) assurance of results, it is certified as having a high level of reliability.
Overall, the SRP can make the examination process much more efficient. The method is based on tried-and-tested testing methods recognized by courts and links these with other analytical approaches to form a systematic network.
development
The SRP has been designed and disseminated since mid-2007 by tax auditor Andreas Wähnert from Schleswig-Holstein in a nationwide network with colleagues. In the financial management of Schleswig-Holstein, the process is trained since 2008 and applied in the audit practice. In addition, Andreas Wähnert and Erich Huber (Head of the "New Testing Technology" department in the Austrian Federal Ministry of Finance ) founded the "New Interactive Testing Technology (NiPt)" working group in 2009 to optimize the use of electronic testing methods. Due to the positive feedback from the practical work in Schleswig-Holstein and the exchange of experience between the tax administrations of Germany and Austria, the SRP is currently being trained and disseminated within the financial administration at the Federal Finance Academy, in almost all federal states, in the federal examination, in parts of customs and the Dutch financial administration.
description
Business (economic) profile
The starting point of an SRP is the recording of operational conditions and data of the company to be audited. From these, in connection with existing industry experience, business-related expectations are determined and a business profile is created. The profile is the prerequisite for a serious assessment of examination results.
In connection with the recognition of the high degree of stability of economic dependencies in business data, justified assumptions are made from the business profile about the level and development of sizes and relationships of tax-relevant data. In addition, it is determined which individual methods can be used to what extent to check the operation.
Important influencing factors for the business profile are the demand situation (e.g. regional conditions and sales channels), especially for absolute success factors of a company (e.g. sales , profit ). Furthermore, operational relationships such as extraordinary fluctuations in the inventory and the frequency of subsequent purchases are important for relations relevant to the audit, such as gross profit mark-up rates, productivity and profitability.
Based on this information, the audit-related taxation data can be a much more accurate assessment of the operational situation and development are made than by the simple comparison of the systematic analysis of performance indicators is possible. Anomalies can be filtered out of the data and then examined for human intervention (design, errors or manipulations). The analysis can also determine drastic changes in the processes or the environment or process weaknesses as well as the overall commercial quality of actions for business advice.
With the previous knowledge of the company-specific conditions such as the company's market presence and the process flows, the overall picture review of the taxation data following the creation of the business profile can be evaluated much more appropriately.
Systematics
At the SRP, business data and internal developments are compared with (internal and economic) experience related to the success content and structural features (e.g. distribution of numbers or values). Interactive correction options (see below) support the joint clarification of implausibilities. This results in a qualified overview of the conclusiveness of the tax bases with the following advantages for the tax audit:
- The probability of detection of errors or tax evasion increases because an overall correct manipulation of the entire operational data is only possible with great effort, which contributes to the quality assurance of the audit.
- The security of the overall result increases because the weaknesses of individual methods are less significant due to multi-perspective safeguards.
For example, a conspicuous commodity time series can be checked according to quarters by displaying it according to months and as a sliding trend analysis.
With the use of the SRP, the tax audit receives the following analysis options with which tax-relevant databases can be examined at the same time:
- Block-by-block review of objects of investigation, for example flow of goods or services, in several perspectives (comparison period and form of presentation) for an expected relationship.
- Year-by-year comparison of individual variables with comparable developments.
- Checking of taxation parameters, which are susceptible to human intervention (design, errors and manipulation), for their number and value distributions.
The process of an SRP usually begins with the examination of long analysis periods (e.g. quarterly gross profit mark-up rates) in order to obtain an overview. In this way, clear trends or major discrepancies are identified. As the accuracy of the test increases, shorter and shorter analysis periods are selected in order to be able to analyze abnormalities more precisely. The various forms of representation (e.g. the comparison of the graphs of purchasing and sales with one-sided scaling of a time series diagram for the absolute relationship versus double-sided for the relative relationship, etc.) gives the company audit the opportunity to compensate for the weaknesses of individual methods and the importance of a To be able to properly appreciate conspicuousness.
At the same time, structural tests of tax audits are used to quickly and effectively reveal human interventions, from contractual arrangements to recording and coding errors to systematic digital manipulations of taxation data (e.g. daily cash receipts). In the structural tests ( Benford's law and logarithmic normal distribution ), a specifically definable and significantly higher level of security (≥ 99%) is used than in the pure assessment of key performance indicators (e.g. comparison of benchmarks or time series analysis ). Anomalies found in the database with structural tests are consequently an indication of manipulation with a probability bordering on certainty or can at least reveal other operational peculiarities that are relevant for the overall view of the company to be checked. Systematic delimitation of homogeneous partial data sets (e.g. years or days of the week) and the combination of different distribution considerations (e.g. chi-square test for the overall and binomial distribution for the single-digit perspective) increases the probability of tax evasion being discovered considerably. The extent to which the distribution ideals on which the structural tests are based are valid is the subject of discussions.
The constant audit experience with SRP in a large number of cases has consistently shown that in the case of redundant, multi-perspective (see below) and interactive (see below) secured inconsistencies, there are regularly serious deficiencies in the records and investigative measures initiated identify tax evasion. The also template-supported estimation option of the SRP (quantile estimation) is based exclusively on the provisions of the financial jurisdiction to prefer internal determination as well as the estimate amount (general principle for the obligation of the tax authorities to go to the upper limit within an estimation framework) and uses the most reliable (scientific) Findings on the scattering behavior with the rank-value relationships of the normal distribution.
automation
The creation of the test results has been automated using SRP templates based on the Microsoft Excel and OpenOffice programs . This has the following advantages:
- The uniform starting point enables a systematic course of the examination.
- The test speed increases significantly compared to a macro-based processing of different test methods.
- The interactivity required for clarifying the facts in mass data can be implemented in a comprehensible manner on the basis of the templates.
A distinction must be made between the two SRP templates "(performance) BWA" and "stochastics". The "(performance) BWA" is used to systematically review two dependent company variables such as B. the flow of goods or services. The template provides an overview of the details of the main tax bases and can be used to examine productivities and other dependencies. In addition, the quantile estimation can be carried out transparently with the help of this template. This is a very important function for the tax audit and the taxpayer , particularly with regard to an actual understanding and the estimation problem , if a joint clarification of the facts cannot be achieved or cannot be achieved to an appropriate extent.
The SRP template “Stochastics” reflects different structures (frequency distributions) of the examined data. Taxation figures are checked with the template for their natural origin and their internal development compared. Problems relevant to practice when checking for a natural origin (e.g. the distinction between uniform distribution ( chi-square test ) and Benford's law , as well as the mathematical evaluability depending on the number of data) are taken into account in the template. In addition, filter options are integrated, which enable a quick selection of partial data sets and intersections in order to be able to examine abnormalities more closely.
The SRP templates were created exclusively for use within the financial administration. However, all printouts for the SRP evaluations contain all the information required to reproduce the results. In this respect, one can certainly take a look at the work of the financial administration.
Interactivity
In tax procedural law, after the spherical responsibility, the tax authorities and the taxpayer must jointly clarify any inconsistencies in an overall picture review of the tax bases.
With the SRP template, it is possible to limit and comprehensibly enter into the database in the event of inconclusive test results, operational peculiarities or other reasons for deviations. This is possible through
- the selective change of the temporal allocation of examined mass data,
- the exclusion of falsifying outlier data sets
- the adjustment of the value content to (relevant) economic fluctuations .
By updating the evaluation results of the SRP templates immediately, the taxpayer and the tax authorities have the opportunity to clarify inconclusive test results with a reasonable amount of effort. Thus, the goal of tax control (§ 88 I AO, § 90 AO, § 145 I AO, § 194 I AO, § 2 I BpO and § 7 BpO) of determining the tax bases as truthfully as possible in a reasonable time can be achieved.
Jurisprudence
In an obiter dictum, the BFH viewed the possibilities of comparing time series very critically and made it dependent on high requirements. The decisive issue concerned the chronological update of the surcharge rate, which summarizes the turnover and purchase or use of goods in one value (here: 10-week "sliding carriage" time series with the highest determined value for the conclusiveness check and estimation of the flow of goods especially for the easy perishable goods in gastronomy). In the SRP, three different time series models are used in a systematic combination in order to obtain a deep insight into the data in a short time. The central time series type "double-scaled comparison of size-adjusted individual graphs (for the two comparison series)" has - compared to the negotiated model -
- Another object of observation: the reactions of the two variables to one another (instead of the "premium rate" factor) and
- different properties: in particular, a much greater stability against interference.
Therefore, the statements of the BFH can only be transferred to the SRP to a limited extent.
redundancy
Discrepancies or anomalies that have not been clarified or can be clarified when checking taxation data reduce the credibility of the taxpayer. The inconsistencies or abnormalities thus have indicative probative value. According to BGH rulings (BGH ruling of April 27, 2010 and BGH ruling of November 25, 1982), the combination of several evidences is more convincing than the individual consideration of the circumstantial facts. A separate discussion of the individual indicators is not sufficient. Rather, the evidence must be considered in an overall assessment. According to the BFH, it is sufficient if the formal errors in cash-intensive companies are serious in their overall view. Then § 158 AO is refuted and the evidence of the tax authorities is generally possible. The jurisprudence does not require any further proof of the extent of the evasion through concrete recalculation, etc. In this case, a roughly simplified estimate by hand is sufficient.
This jurisprudence is of enormous importance for the SRP, because the examination practice often results in several doubts that are secured from multiple perspectives. In the case of manipulated databases, the SRP templates enable the financial authorities to quickly uncover several indications (unexplained, redundant abnormalities), the evidential value of which, according to the Federal Court of Justice, is to be regarded as higher than the (individual) results of statistical mathematical or traditional test methods . It remains to be seen how the BFH rulings will develop specifically in relation to statistical mathematical methods and in particular to the SRP in the future.
outlook
The digital recording and documentation of operational processes (e.g. business transactions, personnel, customer, process and evaluation information) places increasing demands on internal control systems and external audits. In many cases, conventional key figure systems are no longer sufficient for checking operational processes. That is why the financial authorities must also further develop their data analysis programs ( IDEA and ACL), but also integrate other new tools, such as the SRP templates, into the examination practice. The perceptual psychological knowledge that the human brain can process much more information in context from images than from words and numbers is particularly helpful, so that the systematic-dynamic visualization of taxation data has enormous potential for increasing effectiveness and efficiency, including disclosing illegal tax-damaging data Offers profit shifts in corporations.
Internal financial administration trainings of the SRP in various federal states and specific reactions in the literature suggest that the use of the SRP in examination practice will expand significantly in the future.
The future case law of the BFH and the BGH on statistical-mathematical methods and the SRP will be of the greatest importance for the successful application of the SRP in tax audits . The probative value of multiple indicators in taxation and criminal proceedings must also be clarified, as well as the further possibility of using the statistical analysis results as an estimate if necessary.
In principle, the SRP is independent of company size and can be transferred to almost all fields of mass data checking in various industries . The SRP is therefore also to be seen as an introduction to time and resource-based mass data analysis in large companies .
Operational and business considerations / consequences
In the area of checking incomes suspected of evasion, the SRP template can be understood as an up-to-date verification of corporate data that analyzes company-recorded data in a time-saving and largely standardized manner. The situation is different for a company confronted with these test methods (for the first time). If the complex linking options of the systems used in the company were not included in the internal control system (ICS) in advance, nor were any existing "post-processing options for EDP data" and the legal consequences arising from it, then there is usually a lot of time for in the event of a dispute post-processing and understanding of the standardized results sheets from the SRP are required. As mentioned in an earlier review, this expenditure of time is not attributable to the SRP test method.
From a social / entrepreneurial point of view, standardizations that take into account both the legal requirements for digital recording and simplification rules adapted to the latest technical standards could shorten processing times in the interests of both parties.
Technical alternatives
In the area of cash management, technical measures can prevent manipulation and thus relieve the SRP. In Hamburg and Berlin, for example, INSIKA was created as a cryptographic recording system for taxis . Some states require fiscal stores for cash registers .
literature
Legal sources
- Tax Reduction Act of 23 October 2000 (Federal Law Gazette Part IS 1433, Articles 7 and 8)
- Principles of data access and verifiability of digital documents (GDPdU, BMF letter of July 16, 2001, Federal Tax Gazette Part I 2001 p. 415)
- § 158 Tax Code "Evidence of the bookkeeping"
- Application decree to § 158 AO
- Comment on procedural law on the overall picture review (testing), in particular Tipke, Kruse AO / FGO on § 158 AO margin no. 5 (status: serial 123 May 2010), margin no. 17ff (status: serial 123 May 2010)
Books
- SRP manual [updated 2./11. (public / internal financial administration) edition of March 16, 2020] , downloadable from the Schleswig-Holstein state portal under: Schleswig-Holstein / Topics & Tasks / Company audit (digital) - Summary risk assessment .
- Oberfinanzdirektion Nordrhein-Westfalen, in cooperation with the Finanzverwaltung Schleswig-Holstein: Summary Risk Assessment (SRP) and New Examination Technique (NiPt) - Important terms , juris document ID bpnw-FMBP00000777 under the path Fachinfosystem Bp> General Examination Notes > Working Papers and Guidelines ( the document is accessible to users outside the financial administration).
- Harle, Georg / Olles, Uwe: The modern company audit , 3rd edition Herne 2016, publisher: NWB, ISBN 978-3-482-64973-8 .
- Huber, Erich: The new examination technique - mathematical developments , 1st edition Vienna 2009, publisher: LexisNexis ARD ORAC, ISBN 978-3-7007-4309-5 .
- Rau, Simon: Statistical-mathematical methods of tax auditing and structural analysis as a supplementary alternative , 1st edition Lohmar - Cologne, Publisher: Josef Eul, ISBN 978-3-8441-0142-3 .
Individual evidence
- ↑ Wähnert, Andreas: Contemporary data analysis of tax audits - The data auditing network "Summarized Risk Assessment (SRP)" , In: DER BETRIEB 45/2016, pp. 2627–2631.
- ↑ Wähnert, Andreas: Possible uses of new test procedures for financial management - integration of the new test methods in a systematic risk management , In: BBK 15/2009, pp. 738–747.
- ↑ Wähnert, Andreas: Summary risk assessment - Genuine risk management in financial administration with the help of a new examination method , In: StBp 10/2008 pp. 296–299.
- ↑ Wähnert, Andreas: Application of summary methods in electronic tax audits , In: BBK 11/2008, pp. 581–588 and pp. 633–642.
- ↑ Wähnert, Andreas: "Imaging procedures" in (large and group) tax audits - Transparent mass data for correct legal evaluations , In: StBp 2014 pp. 217 - 221.
- ↑ Der Spiegel, Tax haven Germany 40/2013 pp. 74-77.
- ^ Süddeutsche.de: Tax haven Germany , November 7, 2013 .
- ↑ See e.g. B. Enquete Commission of the Bundestag "Vocational training in the digitized world of work", to be read at: https://www.bundestag.de/ausschuesse/weiter_gremien/enquete_bb
- ↑ European Union, General Directorate Taxation and Customs Union: Compliance and Risk Management for Tax Administrations , 2010. (PDF; 747 kB)
- ↑ Pump, Hermann (RiFG a. D.) / Heidl, Wolfgang (StB / FAStR): Assistance with cash management by the tax advisor , In: StBp 2014 pp. 162 - 167, 204 - 210.
- ↑ Becker, Arno: External audit digital - audit methods in focus (Part II) , In: DStR 25/2016, pp. 1430-1436.
- ↑ Wähnert, Andreas: burden of proof and estimates in connection with modern Verprobungsnetzen , In: STBP 4/2011, pp 108 et seq.
- ↑ Schleswig-Holstein Ministry of Finance: Additional results of the tax audit: Mehr Schein als Sein , Item 20.2, 2012. (PDF; 111 kB)
- ↑ Huber, Erich / Wähnert, Andreas: New interactive testing technology (NiPt) - The systematic use of new testing methods in financial management In: NWB 2009 pp. 2814 - 2818.
- ↑ Wähnert, Andreas: Interpretation of time series anomalies - The stability of economic dependencies In: StBp 2014 pp. 97 - 101.
- ↑ Seer: in Tipke / Kruse AO / FGO on § 158 AO, margin no. 17, 136.
- ↑ Wiggen, Martin: The Evidence of the Time Series Comparison , In: StBp 2008, pp. 168–173.
- ↑ Wähnert, Andreas: Meaningfulness and Resilience of Time Series Comparisons - Findings from the New Interactive Testing Technique (NiPt) , In: BBK 9/2013, pp. 420–429.
- ↑ Wähnert, Andreas: interpretation of time series abnormalities - The stability of economic dependencies , In: STBP 2014, pp 97-101.
- ↑ Knief, Peter: Improved early risk detection and creditworthiness analysis through a new "BWA 2008" , In: Risk Manager Special II / 2008, pp. 24–33.
- ↑ Pump, Hermann / Heidl, Wolfgang: Assistance with cash management by the tax advisor , StBp 2014, pp. 162 - 167, 204 - 210.
- ↑ Wähnert, Andreas: Possible uses of new test procedures for financial management - integration of the new test methods in a systematic risk management , In: BBK 15/2009, p. 740 ff.
- ↑ Wähnert, Andreas: Application of summary methods in electronic tax audits , In: BBK 11/2008, pp. 581–588 and pp. 633–642.
- ↑ Wähnert, Andreas: Interactive external audit - possibilities of joint clarification of facts in the digital age , In: Stbg 1/2014 pp. 20 - 27.
- ↑ Huber, Erich: Tax supervision and auditing in the time of the cash android and without INSIKA - basic ideas, goals, risks and second-best solutions , In: StBp 2012 p. 301 - 307, 333 - 339 and StBp 2013 p. 5 - 12, 35 - 43, 71 - 79 and 93 - 101.
- ↑ Härtl / Schieder: Correctness of digitally managed revenue records - Electronic cash registers and digital revenue recording systems in the focus of the tax risk of revenue reduction , In: StBp 2011 pp. 33–40, 68–74.
- ↑ Hill: The Difficulty of Faking Data , In: Chance, Vol. 12, No. 3, 1999, p. 27.
- ↑ Seer in Tipke / Kruse AO / FGO on § 158 AO, margin no. 21b.
- ^ Ehlers: Tax Compliance , In: NWB 18/2012 pp. 1535–1543.
- ^ FG Cologne of January 27, 2009, 6 K 3954/07.
- ↑ Wähnert, Andreas: Burden of Proof and Estimation in Connection with Modern Verprobungsnetzen , In: StBp 4/2011, p. 109.
- ↑ Wähnert, Andreas: Possible uses of new test procedures for financial management - integration of the new test methods in a systematic risk management , In: BBK 15/2009, pp. 738–747.
- ↑ Wähnert, Andreas: Manipulationspsychologie - Can manipulation remain permanently invisible ?, In. StBp 04/2013 pp. 102-105
- ↑ Huber, Erich: Manipulationssysteme, document suppression and corruption of evidence - from system control to general estimation , In: StBp 2003, pp. 193-199.
- ↑ Gebbers, Harald: Die Strukturanalyse , In: StBp 2007, pp. 225-231, 257-263 u. 289-298.
- ^ Brähler, Gernot / Bensmann, Markus / Emke, Anna-Lena: The use of mathematical- statistical methods in digital tax audits , Ilmenauer Schriften zur Betriebswirtschaftslehre 4/2010, Verlag proWiWi eV, Ilmenau, ISBN 978-3-940882-23-3 .
- ^ Nigrini: Taxpayer compliance application of Benford's Law , In: Journal of the American Taxation Association , Vol. 18, No. 1, 1996, pp. 72-91
- ^ The Law of anomalous Numbers , In: Proceedings of the American Philosophical Society 78/1938, No. 4, pp. 551-572.
- ↑ Wähnert, Andreas: Logarithmic normal distribution as a test tool for economic data - The logic of an efficient distribution pattern , StBp 1/2016, pp. 1–6.
- ↑ Wähnert, Andreas: The Evidence of the New Interactive Examination Technique (NiPt) - Chi-Square Test and Comparable Procedures in Company Audits , In: BBK 8/2014 pp. 380 - 391.
- ↑ Gebbers, Harald: Analysis of the jurisprudence on the chi-square test in the field audit - application for the examination of revenues and logbooks , In: StBp 2008, pp. 209-214 u. 290-296.
- ↑ Wähnert, Andreas: The digit analysis as a component of contemporary audit approaches , In: StBp 2012 pp. 241 - 246.
- ↑ Wähnert, Andreas: Possible uses of new test procedures for financial management - integration of the new test methods in a systematic risk management , In: BBK 15/2009, pp. 738–747.
- ↑ Wähnert, Andreas: The great potential of structural comparison in the revision , In: SteuerConsultant 4/2012, pp 18-23.
- ↑ Petersen, Tim: Benford's Law and the Tax Audit - A response to Wähnert's "Interactive External Audit - Possibilities of Joint Clarification of Facts in the Digital Age" (Stbg 2014 p. 20 ff.) From a scientific historical perspective , In: Stbg 2015, pp. 506-511 ; Wähnert, Andreas: An answer to Petersen's "science-historical" view of Benford's Law: Appropriate standards for the new examination technique , In: Stbg 2015, pp. 511-516; Petersen, Tim: "False alarm" - an answer to Andreas Wähnert's reply and "Clarification" , In: Stbg 2015, pp. 516–519.
- ↑ Webel, Karsten / Wähnert, Andreas: The suspicion of a tax offense during the field audit - § 10 BpO in the context of digitization , In: NWB 44/2014, pp. 3324–3334.
- ↑ Seer in Tipke / Kruse AO / FGO on § 158 AO, margin no. 24.
- ↑ Madauß, Norbert: Statistical-mathematical methods in taxation and criminal tax proceedings, In: NZWiSt 1/2014 pp. 24-26.
- ^ FG Hamburg, decision of August 26, 2016, 6 V 81/16.
- ^ FG Münster of August 19, 2004, 8 V 3055/04, EFG 2004 p. 1810.
- ↑ BFH of March 9, 1967, IV 184/63, BStBl. 1967 III p. 349.
- ↑ Schumann, Jan Christoph / Wähnert, Andreas: The quantile estimation - estimation based on an objectified performance measure, In: Stbg 12/2012 pp. 535 - 539.
- ↑ Graf, Olaf: Data analysis and obligation to cooperate in tax audits - a symbiosis? , In: BBK 7/2012, pp. 331–341
- ↑ Schumann, Jan Christoph / Wähnert, Andreas: The quantile estimation - estimation based on an objective performance measure, In: Stbg 12/2012, pp. 535-539.
- ↑ Wähnert, Andreas: Possible uses of new test procedures for financial management - integration of the new test methods in a systematic risk management , In: BBK 15/2009, p. 740 ff.
- ↑ Huber, Erich: Manipulationssysteme, document suppression and corruption of evidence - from system control to general estimation , In: StBp 2003, pp. 193-199.
- ↑ Gebbers, Harald: Die Strukturanalyse , In: StBp 2007, pp. 225-231, 257-263 u. 289-298.
- ^ Brähler, Gernot / Bensmann, Markus / Emke, Anna-Lena: The use of mathematical- statistical methods in digital tax audits , Ilmenauer Schriften zur Betriebswirtschaftslehre 4/2010, Verlag proWiWi eV, Ilmenau, ISBN 978-3-940882-23-3 .
- ↑ Gebbers, Harald: Analysis of the jurisprudence on the chi-square test in the field audit - application for the examination of revenues and logbooks , In: StBp 2008, pp. 209-214 u. 290-296.
- ^ Nigrini: Taxpayer compliance application of Benford's Law , In: Journal of the American Taxation Association , Vol. 18, No. 1, 1996, pp. 72-91
- ^ The Law of anomalous Numbers , In: Proceedings of the American Philosophical Society 78/1938, No. 4, pp. 551-572.
- ↑ Wähnert, Andreas: Possible uses of new test procedures for financial management - integration of the new test methods in a systematic risk management , In: BBK 15/2009, p. 743 ff.
- ↑ Seer in Tipke / Kruse AO / FGO on § 158 AO, margin no. 14th
- ↑ Gräber, FGO, 7th edition, § 96 FGO with further references.
- ↑ Wähnert, Andreas: Evidence of systematic-redundant Verprobungsansätze , In: NWB 37/2010, p. 2964 f.
- ↑ Wähnert, Andreas: The burden of proof in the taxation process - focus " Entrepreneurship " , In: SteuerConsultant 11/2011, pp. 16-19.
- ↑ BFH of March 25, 2015 - XR 20/13.
- ↑ Nöcker, Gregor (RiBFH, X. Senate): time series comparison in the sliding carriage versus programming protocols of the cash register - comments on the BFH judgment XR 20/13 and some more , In: NWB 48/2015, pp. 3548–3557.
- ↑ Wähnert, Andreas: Contemporary data analysis of tax audits - The data auditing network "Summarized Risk Assessment (SRP)" , In: DER BETRIEB 45/2016, pp. 2627–2631.
- ↑ Wähnert, Andreas: The difference between time series models - How much time series variants differ in the examination application , StBp 3/2016, pp. 61–66.
- ↑ Pump, Hermann / Wähnert, Andreas: The BFH judgment on time series comparison as a verification and estimation method, In: NWB 39/2015, p. 2869 f.
- ↑ Becker, Arno / Giezek, Bernd / Webel, Karste / Wähnert, Andreas: The reason for complaint according to § 158 AO , DStR 32/2016, pp. 1878–1885.
- ^ BGH judgment of April 27, 2010, 1 StR 454/09.
- ↑ BGH judgment of November 25, 1982 - 4 StR 564/82.
- ↑ Wähnert, Andreas: The underrated importance of lines of evidence in the audit practice in: BBK 24/2011, pp 1187-1192.
- ↑ Buse, Johannes: Selected decisions on criminal tax law , In: StBp 2012, p. 108 ff.
- ↑ Wähnert, Andreas: The underestimated importance of chains of evidence in examination practice In: BBK 24/2011, p. 1192 f.
- ↑ Wähnert, Andreas: The great potential of structural comparison in the revision , In: SteuerConsultant 4/2012, p. 23.
- ^ Rau, Simon: Statistical-mathematical methods of tax auditing and structural analysis as a supplementary alternative , p. 66 f., 2012, 1st edition Lohmar - Cologne, publisher: Josef Eul, ISBN 978-3-8441-0142-3 .
- ↑ IDW PH 9.330.3, Use of data analyzes , status: August 24, 2010, FN-IDW 1/2011, p. 59 ff., In: WPg Supplement 1/2011 , p. 35 ff.
- ↑ Huber, Erich / Reckendorf, Jens / Zisky, Norbert: The immutability of (cash) bookkeeping in accordance with Section 146 (4) AO in the IT era and INSIKA , In: BBK 12/2013, pp. 567 - 579, BBK 13 / 2013 pp. 610 - 620 and BBK 14/2013 pp. 663 - 678.
- ^ "Principles for the proper management and storage of books, records and documents in electronic form as well as for data access (GoBD)" , BMF letter of November 14, 2014
- ↑ Wähnert, Andreas: The great potential of structural comparison in the revision , In: SteuerConsultant 4/2012, p. 19 ff.
- ↑ Wolenski, Volker / Weiskopf, Jörg: Use of indirect audit methods in large-scale company audits using the example of individual value adjustments, In: BBK 03/2013 pp. 128–133.
- ↑ Barnard, Fred R .: One look is worth a thousand words , published in a US-American magazine of the advertising industry in 1921: read under: A picture is worth a thousand words .
- ↑ Werner, Stefan / Wähnert, Andreas: Illustrative examination using the example of profit shifting - the superiority of the visualization of data rules and distributions over key figures , IStR 19/2016, pp. 811–814.
- ↑ Wolenski, Volker / Wähnert, Andreas: Systematic visualization of international profit shifts - examples of improved possibilities through new interactive testing technology (NiPt) , In: IWB 3/2015, pp. 105–111.
- ↑ Wähnert, Andreas: "Imaging procedures" in (large and group) tax audits - transparent mass data for correct legal evaluations In: StBp 2014 pp. 217 - 221.
- ↑ Pump, Hermann / Heidl, Wolfgang: Assistance with cash management by the tax advisor , StBp 2014 pp. 162 - 167.
- ↑ Madauß, Norbert: Statistical-mathematical methods in taxation and criminal tax proceedings, In: NZWiSt 1/2014 pp. 24-26.
- ^ Rau, Simon: Statistical-mathematical methods of tax auditing and structural analysis as a supplementary alternative , p. 66 f., 2012, 1st edition Lohmar - Cologne, publisher: Josef Eul, ISBN 978-3-8441-0142-3 .
- ↑ Wähnert, Andreas: The great potential of structural comparison in the revision , In: SteuerConsultant 4/2012, p. 23.
- ↑ Deggendorfer Forum for digital data analysis eV (ed.), Digital data analysis, internal auditing and auditing, using synergies - optimizing audits , 2009, Erich Schmidt Verlag, ISBN 978-3-503-12633-0 .
- ↑ Weiskopf, Jörg / Wähnert, Andreas: Transfer Effects of Modern Verification Approaches to the Large- Scale Company Audit In: BBK 3/2012, pp. 127-133.
- ↑ Entry by the Federal Finance Academy of March 10, 2014 under “News”, read under: Archived copy ( Memento of the original from November 2, 2014 in the Internet Archive ) Info: The archive link was inserted automatically and has not yet been checked. Please check the original and archive link according to the instructions and then remove this notice.
- ↑ E.g .: Wähnert, Andreas: Significance and reliability of time series comparisons, In: BBK 09/2013 pp. 421–429 with additional references
- ^ Graf, Olaf: Requirement for the submission of individual records, In: BBK 18/2013 875–882
- ↑ Pump, Hermann: Legal consequences when using manipulation software (zapper software), In: DStZ 09/2013, pp. 299-306.
- ↑ Huber, Erich / Reckendorf, Jens / Zyski, Norbert: The immutability of (cash) bookkeeping in accordance with Section 146 (4) AO in the IT era and INSIKA, In: BBK 12–14 / 2013, pp. 568–579, 610-620, 663-678.
- ^ Graf, Olaf: Requirement for the template, ibid for the discussion of data output from merchandise management systems