TAX – Compliance Management Systems

FMC guides you over the hurdle of a TAX-CMS by using specialists in all subject areas.

Why a TAX-CMS (fiscal risk control system)

The three most common reasons for setting up a fiscal risk control system are:

  • it follows from the legality control obligation of the business supervisory bodies that an effective tax compliance management system must be in place.
  • a lack of a tax risk control system usually leads to a liability exclusion of a D&O insurance.
  • by decree of the Federal Minister of Finance in 2016, the rules on retrospective changes to tax returns under § 153 AO were tightened. An internal control system is expressly mentioned here as a possible mitigating factor.

Overview of a TAX-CMS (no completeness / company-specific deviations possible)

Project flow and effort for the installation of aTAX-CMS [external services (in blue) also internally possible (red)]


The results of the risk analysis workshops (2.) are used to create the risk control matrix (3.a). Coarser or finer grids can be selected for the risk level and probability of occurrence. The following example has five damage levels (0 = none, 1 = very low, 2 = low to medium, 3 = high, 4 = very high) whose amounts can be freely selected. For the probability of occurrence, 5 grids were also selected (0 = none, 1 = very low, 2 = low to medium, 3 = high, 4 = very high) whose percentages are also freely selectable.

For many risks, the actual amounts of damage can and must be determined. In point 3.b) a correct calculation per risk is made.

Already existing risk minimization concepts are documented and checked in point 3.c).

  • Basic Principles (e.g. tax guidelines)
  • Measures (e.g. work instructions and special documents)
  • Controls (e.g. 4-eye principle etc.)

The aim of a TAX-CMS project is to minimize the probability of risks occurring. For this purpose, necessary minimization activities are designed depending on the risk level (3.d).