Tax compliance practice: Emails as commercial and business letters to be submitted in an external audit (BFH ruling of April 30, 2025 – XI R 15/23)

The current Federal Fiscal Court ruling (XI R 15/23 of April 30, 2025) clarifies that emails can be tax-relevant commercial and business correspondence. Companies must submit such emails during tax audits if they relate to contract content or tax-relevant information. However, a blanket “overall journal” of all emails remains inadmissible.

The decision brings relief, but also responsibility: anyone who does not clearly organize and document tax-relevant emails risks additional work in the event of an audit.

This article by POELLATH professional Nina Matlok highlights the practical implications and shows how companies should prepare now.