III. Expert Committee

Standardization of transactional information requirements

Chair: Jan Körner, BASF
Vice Chairmen: Michael Fuhr (EY), Benjamin Koller (BDI)


Mission: The mission of this technical committee is to develop standards for existing or future transactional information requirements, taking into account international developments (e.g. SII, SdI). This also includes current and future standardization efforts in the area of data access in the context of tax audits (e.g. OECD SAF-T, Standard Audit File – Tax).


Focal points: Currently, a very dynamic development in the area of transactional VAT reporting obligations can be observed both at EU level (see e.g. Commission Action Plan of 15.7.2020 or FISCALIS seminar “VAT in the Digital Age”) and at Member State level. There is a clear trend towards the establishment of new information obligations that require providing transaction data and increasingly in real-time or near real-time. The procedural shifting in time of verification requirements is accompanied by increasingly data-based tax audits that evaluate transactional data (e.g. Section 4 (2a) Wage Tax Executing Regulation). The differing national implementation of approaches such as SAF-T are costly and associated with the risk of compliance violations. The expert committee is therefore examining international developments on transactional information requirements (example Italy) and evaluating the effects of a possible transfer into national law. It is also addressing the question of how the hitherto largely lacking standardization of data access law for tax audits (Z3 access, as in the 2020 draft of a Section 147b General Tax Code) can be overcome and whether the verification of transaction data can be supported with the help of new technologies (e.g. distributed ledger).