§ 139 Tax Act (StG) - Access to Files

1. Taxpayers are entitled to inspect the files submitted or signed by them. Spouses who are jointly assessed have a mutual right to inspect each other's files.

2. The remaining files are open for inspection by the taxpayers, provided that the investigation of the facts has been completed and there are no public or private interests opposing it.

3. If a taxpayer is denied access to a file, it may only be used to their detriment if the authority has informed them orally or in writing of the essential content relevant to the matter and has also given them the opportunity to express comments and identify counter-evidence.

4. Upon the taxpayer's request, the authority confirms the denial of file inspection by issuing a ruling, which may be appealed through an administrative court complaint.

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