Section 153(4) AO: Why VAT audits can also affect Insurance Premium Tax
Since 2025, tax audit findings can have implications well beyond the tax originally audited. Section 153(4) of the German Fiscal Code (AO) requires taxpayers to apply audit findings implemented in assessments that have become final and binding to other tax returns, even where these relate to different taxes or periods not previously audited. The interaction between VAT and Insurance Premium Tax (IPT) is particularly sensitive. Under section 4 no. 10 of the German VAT Act (UStG), a single set of facts can affect both tax regimes. This article explains the new compliance obligations, highlights areas of uncertainty in interpreting the rules and outlines how businesses can manage the associated risks systematically.
