Assume as a starting point that there is a tax control at a business partner. The foreign authority questions an invoice or there is a request by third countries for cooperation; they send a standardized first questionnaire which may contain even trick questions that cannot be answered properly (e.g. „what was the purchase price of your supplier? “).

  • Go through the questions in the following checklist: make sure there are proper answers and that documentation is always up to date, then there will rarely be big surprises

1. General Information

  1. Extent of economic activity during the relevant period
  2. Ultimate beneficial ownership (include chart)
  3. Place of effective Management (board meetings, files)
  4. What was the relationship to company CCC?

2. Contracts / Services

  1. Was Mr. UBO employed in the company in the period
  2. If yes,
    • in which location the employment was undertaken
    • provide breakdown of the employment income
    • Submit a copy of the social security and tax declaration
  3. Explain if there were any fringe benefits or allowances
  4. Has there been any agreement for services by Mr. UBO to the company; were provisions paid to him or related parties?
  5. Please provide supporting documentation

3. Business Transactions

  1. Have there been any business transactions with CCC?
  2. If yes, kindly
  • provide a breakdown of all business transactions
  • provide matching invoices
  • Indicate in which accounts these transactions are reflected in the bookkeeping
  • Inform about other transactions the company may have undertaken involving Mr. UBO either directly or indirectly
  • If applicable, inform who signed the agreements
  • Inform if accounting is done in house or outsourced

4. Payments

  1. Information on the formalities used to conclude transactions between the company and Mr. UBO or CCC
  2. Breakdown of any debts outstanding to and from the above-mentioned parties during the relevant period
  3. Information how each of the payments were made (bank, cash, credit card etc.)
  4. Information who made and authorized the payments

5. Loans

  1. contract details (purpose, lender, period, amount, interest)
  2. Are borrower and lender associated parties?
  3. How was the loan made / paid (bank, cash, asset transfer)?
    • from which account it was paid by the lender (IBAN)?
    • on which account it was received by the borrower (IBAN)?
  4. Guarantee and the terms of guarantee
  5. Interest payments: amounts and dates
  6. Repayment: Amounts and dates of full or partially repayment
  7. Information how the loan was financed

6. Business Relation

  1. On what occasion happened the contact to the company CCC?
  2. Which other companies did the company ask for competitive offers for the planned services? Why was this supplier selected? Was this documented?
  3. What kind of economic benefit resulted in the relationship to this company?
  4. Who were suppliers before this selection? What was the reason to change?
  5. Did the company ask for information about the reliability of the foreign company? Since when is this company registered as VAT payer? Who was approached, which information was received?
  6. Provide extract of the commercial register and address of the shareholders
  7. What is the profession and the industry- specific education of the management?
  8. How is the foreign business organized?
  9. Which website has the company?
  10. In which industry registers can the company be found?

7. Proof of Services

  1. How was the agreement with the supplier concluded?
  2. How did the supplier prove that the services have really been performed?
  3. How did the services create a value for the company?
  4. How were the services documented (time sheets, protocol of meeting, reports etc)?
  5. Which physical persons were providing the services, – please provide names, addresses and qualification?
  6. How and when were the services paid
  7. Who is the final beneficiary of these payments?