Dossier and expert report
A piece of evidence you can recalculate.
An expert report is worth as much as it can be verified. Not as much as it asserts, and not as much as its author weighs. We record every incoming invoice of the audit period — not a selection — store the recipe for every product, calculate from that the quantity actually produced and from that the sale. Every figure leads back to a document, every calculation is disclosed.
Two documents, two tasks
The expert report establishes facts and leaves the appraisal to the court. It is deliberately neutral — a report that tells the court how to decide oversteps its task and thereby weakens itself. The dossier around it orders timelines, contradictions and courses of action for the decision. Both in one volume — the evidence and the strategy, but cleanly separated.
What a usable expert report needs
The provisions in this table are German law. Most European legal orders know the same principle — set out verbatim and by country in the register of legal bases.
| Property | What it means | Legal anchor |
|---|---|---|
| Complete | not an extract but the whole period | § 162 Abs. 1 Satz 2 AO — all material circumstances |
| Traceable | every figure leads back to an individual document | § 96 Abs. 1 Satz 1 FGO — the overall result of the proceedings |
| Reproducible | a third party arrives at the same result | § 76 Abs. 1 Satz 1 FGO — the court investigates the facts of its own motion |
| Neutral | including what speaks against the client | § 76 Abs. 1 Satz 3 FGO — statements complete and truthful |
| In time | before the set deadline expires | § 79b Abs. 3 FGO and § 364b Abs. 2 AO — preclusion |
| Followable without special software | the calculation is disclosed | The precondition for a court-appointed expert to be able to examine it at all |
Qualified party submission, not expert evidence
A report commissioned by a party is not court expert evidence — an expert within the meaning of § 81 Abs. 1 Satz 2 FGO is someone the court calls in. It is qualified party submission: factual submission supported by documents. That is not a disadvantage. Substantiated submission underpinned by figures and documents sets the official investigation under § 76 Abs. 1 Satz 1 FGO in motion — and can give cause to appoint an expert of the court.
What a dossier is not
It is neither legal advice nor representation. We establish the facts and calculate; the legal appraisal and the representation stay with your tax adviser and your legal representatives. A report that blurs this line is attacked on that ground first.
What we contribute
We deliver both in one volume: the expert report as evidence and the dossier as a basis for decisions. The raw data are open and the calculations are documented so that recalculation is possible without special software.
The legal provisions cited here are given for information and do not replace legal advice.