Overview Of The BMF Instruction Sheet On Cross-Border Audit Cooperation

German Federal Ministry of Finance (BMF) recently released an instruction sheet on cross-border audit cooperation with tax administrations of other countries (dated May 15, 2025). The document outlines legal foundations, administrative procedures, and practical implementation of joint audits, simultaneous audits, and the presence of tax officials in the international tax audit context. It replaces the earlier 2017 version and supplements guidance on international administrative assistance under the EU framework and bilateral tax treaties.

The information sheet defines three principal forms of cross-border audit cooperation:

• Joint Audit: A coordinated audit involving German and foreign competent tax authorities with the goal of reaching mutual agreement on the facts and circumstances under examination and to reach a consensus on their tax implications based on the agreed facts. This form is particularly suitable in cases where unilateral actions may lead to