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Tax assessment provisional or subject to review: what does it mean?

Many tax assessments are not issued as final but as provisional or subject to review. Both mean that the assessment can still be changed later, in your favor or to your disadvantage. Knowing this helps you gauge deadlines and risks.

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Your chances of getting your money back

If an assessment is subject to review, it can be changed at any time within the assessment period (§ 164 AO). A provisional note, by contrast, only affects certain points named in the assessment (§ 165 AO).
The provisional status can benefit you: if a point depends on a pending model case, you automatically benefit from a later favorable decision without having to file an appeal yourself.

What you should do now

  1. 1

    1. Read the note

    Check whether and to what extent the assessment is provisional or subject to review.

  2. 2

    2. Clarify the scope

    Determine which points remain open and which are final.

  3. 3

    3. Secure your own points

    For final, disputed points, file an appeal on time if necessary.

  4. 4

    4. Wait for the change

    For provisional points you often need do nothing; the adjustment happens later.

How to spot the scam

  • A final, disputed point becomes binding for lack of an appeal.
  • The reach of the provisional note is overestimated.
  • No preparation is made for a later change to your disadvantage.

Frequently asked questions

What does 'subject to review' mean?

The entire assessment stays open and can be changed at any time within the assessment period, in both directions (§ 164 AO). The tax office uses this to assess quickly first and review more closely later. During this time you can likewise apply for a change.

What does 'provisional' mean?

The provisional note only affects certain points named in the assessment, for example those depending on a pending model case (§ 165 AO). Only those points stay open; the rest of the assessment becomes final if you do not file an appeal.

Do I have to file an appeal myself for provisional points?

For the points set as provisional, usually not: you automatically benefit from a later favorable clarification. For final points you consider wrong, however, you must file an appeal on time within one month, otherwise they become binding.

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General information for self-help, not legal advice (RDG). In case of a high loss or uncertainty: contact a consumer advice center or a lawyer.