// IMMO.QUICK · GATETAXADMINISTRATION · § 88 ABS. 5 AO · VOLLAUTOMATISIERTE STEUERFESTSETZUNG

Externally secret, internally complete. Two layer transparency.

gateTaxAdministration checks fully automated tax assessment under section 88(5) of the German Fiscal Code. The law allows the tax authority to keep risk management parameters secret, but requires random sampling, exclusion logic, and an internal audit trail. The gate publishes no parameters, it only certifies that the legally required control mechanisms exist.

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Test result: BLOCK. 2 of 2 test cases passed, missing control mechanisms lead to block, not human escalation.

✓ RELEVANT IF...

You operate a risk management system for fully automated tax assessments and need to demonstrably carry the legal controls

× NOT RELEVANT IF...

Assessments are issued manually or without a risk management system under section 88(5), then the gate honestly returns pass with applicable: false

// Architecture

Legal basis as hard flags.

Every row is a hard boolean check, not probabilistic scoring. A critical failure leads to block, a high severity failure to warn, everything else to pass.

Reference	Checks	Severity
§ 88 Abs. 5 S. 2 Nr. 2 AO	Random sample quota for manual review documented	critical
§ 88 Abs. 5 S. 2 Nr. 3 AO	Exclusion logic removes suspicious cases from full automation	critical
§ 88 Abs. 5 S. 3 AO	Internal audit trail for the court of audit and data protection authority, secret externally, complete internally	critical
§ 155 Abs. 4 AO	Automated assessment issuance correctly referenced	high
§ 355 AO	One month appeal deadline correctly communicated	medium

// Worked examples

Four inputs, four outcomes.

No example is hypothetical, each is an actual test case from the test suite report.

Example 1 · Nexus not met

No risk management system in use

PASS applicable: false

Section 88(5) only applies to risk management systems. Without one, the gate is honestly not applicable.

Example 2 · Critical, all three controls missing

No random quota, no exclusion logic, no internal audit trail

BLOCK 3 critical flags

Tax does not touch the subsistence minimum, an assessment can be appealed. Hence block instead of human escalation: this system may not assess fully automatically.

// Clarification

What gateTaxAdministration is not.

Not a publication of risk parameters. That is legally permitted secrecy, the gate does not break it.
Not MANDATORY_HUMAN_REVIEW. Tax assessments are appealable without the citizen facing existential risk, a block suffices.

Externally secret, internally complete. Two layer transparency.

Legal basis as hard flags.

Four inputs, four outcomes.

What gateTaxAdministration is not.

For tax authorities that want to provably document their risk management system's legally required controls without disclosing the parameters.