StartInternat. Tax LawInternational Exchange of InformationGroup Enquiries

Group Enquiries

An effective tool for tax investigations in foreign countries! LHP Attorneys inform and advise on group enquiries under international administrative assistance. 

A current topic in the area of international administrative assistance are group enquiries (international exchange of information). Germany has agreed with other countries on a number regulations for this purpose, which remain to be implemented in national law. This instrument will enable Germany to obtain large amounts of information with little effort (one letter suffices). This investigative measure is being discussed in respect of so-called slush fund accounts in foreign countries. Group enquiries are however not limited to this area. Other income and group-specific situations may also be concerned. Group enquires may, for example, also target groups of fee-based physicians with income from self-employment.

Group enquiries: definition and limitations

The term group enquiry will be explained in detail to assist in a better understanding of current reports in the press. Note: Reports in the press about group enquiries do not give rise to an estoppel for a voluntary self-disclosure! It takes the discovery of an offence, which is one of many possible estoppels. This means, that a voluntary self-disclosure should be discussed on a case-by-case basis.

What are group enquiries?

Limitations for group enquiries

Legal remedies / defence against group enquiries, prohibition of exploitation

LHP Attorneys will continue to follow future developments.

The discussion about group enquiries is very active. Tax Authorities also hope for information by way of the automatic exchange of information in the near future. It remains to be seen, whether the investigative authorities will use the controversial measure of group enquiries or simply reap the rewards from the automatic exchange of information. LHP Attorneys in Cologne and Zurich will continue to follow future developments.

LHP: Attorneys at Law, Tax Law Specialists, Tax Advisers PartmbB


An der Pauluskirche 3-5, 50677 Cologne,
Telephone: +49 221 39 09 770


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Telephone: +41 44 212 3535

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