Findings at a glance
- Traceability of the calculation
- Completeness of the data basis
- Business-specific benchmark
- Requirements for counter-evidence
- Burden of proof and its reversal
- Official benchmark tables
- Data access and format
- Intensity of judicial review
5× exceeded · 3× met
Traceability of the calculationexceeded
The indirect assessment must be reasoned; the report must set out the methods and the calculations.
CitationLey 58/2003 (LGT) art. 53 · art. 158
What we provideEvery figure is traceable down to the individual document. The chain of calculation can be walked in both directions — from the result to the document and back.
Completeness of the data basisexceeded
Sector data, comparable businesses and indicative evidence are permitted; a full survey is not required.
CitationLey 58/2003 (LGT) art. 53.2
What we provideA full census across all accounts, suppliers and product groups. No sampling is used; 100 per cent is the upper limit and cannot be exceeded by any method.
Requirements for counter-evidenceexceeded
Evidence may be adduced against the report on the indirect assessment.
CitationLey 58/2003 (LGT) art. 158.3
What we provideA closed system: purchasing, production, masses, unit counts, sales channel and revenue support one another. A single incorrect figure shows up against the others.
Further information — 5 axes
Business-specific benchmarkexceeded
The objective assessment regime works with modules (floor area, staff, consumption) rather than with the business’s own data.
CitationLey 35/2006 (IRPF) art. 31 · jährliche Orden HFP
What we provideThe calculation rests on the recipes and quantities of the audited business, not on an industry average.
Burden of proof and its reversalmet
Indirect assessment presupposes that the tax base cannot be determined by any other means.
CitationLey 58/2003 (LGT) art. 53.1
What we provideThe evidence is prepared so that the reversal of the burden remains traceable and the counter-evidence engages with the calculation, not with the objection.
Official benchmark tablesexceeded
Módulos and sector figures published by the AEAT.
CitationOrden HFP (jährlich) · AEAT
What we provideThe actual mark-up of the business is determined and set against the official figure — with a reasoned classification.
Data access and formatmet
Production of the accounts and near-real-time turnover data under the SII.
CitationReal Decreto 596/2016 (SII) · LGT art. 142
What we provideOutput in the audit formats required by the respective country; the raw data is preserved unchanged.
Intensity of judicial reviewmet
Review by the economic-administrative tribunals and the administrative courts.
CitationLey 58/2003 (LGT) art. 226 ff.
What we provideThe dossier is built so that a court can follow it without having to calculate anything itself.