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The Federal Ministry of Finance has published the draft of the new Tax Audit Regulations. These are to replace the current tax audit regulations and place a stronger focus on risk-based audits, faster proceedings and more duties on companies to cooperate.

Businesses may face serious risks in criminal tax law after the Federal Court of Justice (BGH) ruled on 10 December 2025 (1 StR 387/25) to change its previous case law. Incorrect preliminary VAT returns and a related incorrect annual return no longer count as a single offence. Instead, the offences stand next to each other and are to be evaluated under criminal law separately. This results in a considerable tightening of the legal consequences to taxpayers and all those involved in the preparation and submission of preliminary VAT returns and annual returns.