Answers / Financial Due Diligence

What are the key differences between FDD in the US and Germany/DACH?

An advanced Financial Due Diligence question — expect it in final rounds and case-heavy interviews (IB, PE, Big-4 Transaction Services).

THE SHORT ANSWER

Germany: greater emphasis on HGB vs. IFRS differences, Handelsregister/Bundesanzeiger as data sources, Kurzarbeit and government subsidy programs, stricter employee termination laws affecting restructuring costs, GewSt/KSt tax structure complexity, and different working capital norms (German Mittelstand often has longer payment terms). Also: IDW standards may apply if FDD feeds into a formal valuation.

WHAT INTERVIEWERS LISTEN FOR

  • HGB vs. IFRS accounting differences
  • Public register data sources (Handelsregister, Bundesanzeiger)
  • Kurzarbeit and government subsidies impact
  • Strict employee termination laws
  • Trade tax (GewSt) complexity and working capital norms

COMMON MISTAKES

  • Overlooking HGB adjustments when comparing to US GAAP
  • Ignoring local tax implications (GewSt, KSt)
  • Assuming same working capital cycles as US

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