ED10 - Sphere Classification of Business Transactions (from Trade Registration, with Non-Profit Status)

Problem

A non-profit organization registers a trade - and from that moment on, sphere separation (§§ 51–68 AO) applies. But in practice:

• "Spheres? Never heard of them." - many non-profit entrepreneurs do not know that they must assign every business transaction to one of four spheres
• Mixing of ideell and wirtschaftlich - workshop income (ideell) and merchandising sales (wirtschaftlich) end up in the same account, the same folder, the same repo
• No sphere labeling - journal entries have no field indicating the sphere - the auditor has to guess
• Asset mixing as grounds for revocation - § 55 Abs. 1 Nr. 5 AO threatens revocation of non-profit status in the event of asset mixing - retroactively up to 15 years
• No automatic verification - nobody checks whether every business transaction has a sphere - the assumption is "it will somehow be fine"
• Allowances misassigned - volunteer and instructor allowances (§ 3 Nr. 26/26a EStG) are not assigned to the correct sphere

Trigger A - Trade Registration: This obligation arises without employees - it is part of the organization, not of its existence as an employer. From the moment a non-profit organization registers a trade, every business transaction must be assigned to a sphere.

Core Statement

Sphere classification in the Git repo means:

1. Every business transaction has a sphere field - mandatory field, not optional (for non-profit tenants)
2. Four spheres - ideell, vermögensverwaltend, zweckbetrieblich, wirtschaftlich
3. Pre-commit hook checks completeness - no commit without a sphere tag for non-profit tenants
4. Sphere violation report - automatic warning for a wirtschaftlich transaction in an ideell context
5. Allowances assigned - volunteer/instructor allowances (§ 3 Nr. 26/26a EStG) receive a sphere tag

Compliance by Design: Sphere separation does not come about through subsequent sorting, but through structural mandatory fields and pre-commit hooks that check every business transaction for sphere assignment.

The Four Spheres

Risk of Missing Sphere Separation: Asset mixing (§ 55 Abs. 1 Nr. 5 AO) is grounds for revocation of non-profit status. A non-profit organization that does not separate wirtschaftlich and ideell transactions risks revocation of its non-profit status - and with it, subsequent taxation of reserves (retroactively up to 15 years).

Sphere Classification in the JSON Artifact

Every business transaction (journal entry, diary entry, voucher) contains the sphere field as a mandatory field for non-profit tenants:

{
  "$schema": "https://gitcover.org/schemas/diary-entry-1.0.schema.json",
  "V7GUID": "<V7GUID-Class-aus-Registry>",
  "uuidV7": "<uuidV7-Object-mit-vorgegebener-Zeitmarke>",
  "author": "E1",
  "role": "Buchhalter",
  "tenant": "ORG-1",
  "sphere": "ideell",
  "source": "E1",
  "source_sha256": "<SHA-256-...>",
  "tags": ["workshop", "bildungsangebot"]
}

Note: The uuidV7 is the DocID of the entry. The composite key V7GUID:uuidV7 is used for storage organization and DB queries. The sphere field is a mandatory field for non-profit tenants - the pre-commit hook checks its presence and validity.

Pre-Commit Hook Checks Sphere Completeness

Important - Warning vs. Rejection: A sphere violation (wirtschaftlich transaction in an ideell context) results in a warning, not a rejection - the transaction may be legitimate (e.g., a commercial business that belongs to the corporation). But the warning forces the entrepreneur to consciously confirm the classification and document it in the commit.

Sphere Report

The post-commit hook generates a sphere report per fiscal year:

Practical Example: The entrepreneur (E1) books a merchandising sale (wirtschaftlich, 500 EUR) and a workshop (ideell, 200 EUR). The pre-commit hook requires sphere: "wirtschaftlich" or sphere: "ideell" respectively. The post-commit hook generates a report: wirtschaftlich 500 EUR (below the threshold), ideell 200 EUR. If the threshold is exceeded, the report warns of corporation tax liability.

Allowances and Spheres

Volunteer and instructor allowances (§ 3 Nr. 26/26a EStG) must be assigned to the correct sphere:

Important: The allowances are tax-free - but only if they are assigned to the correct sphere. A volunteer allowance in the commercial business is not tax-free. The sphere field in the diary entry documents the assignment.

Articles of Association § 6a: The payout of the allowances requires an opening clause in the articles of association (§ 6a). Until the amendment to the articles of association is entered in the commercial register, the payout is to be deferred - the entitlement arises from the date of the amendment to the articles of association. See ED11 for details.

Risk Leverage

Harness Requirement (Preview)

Derivable from ED10:

The complete list of requirements in Harness-Anforderungen.md.

Sources

• AO (§ 52 - non-profit status, § 55 Abs. 1 Nr. 5 - asset mixing, § 58 Nr. 1 - vermögensverwaltend, § 64 - commercial business, § 64 Abs. 3 - threshold 45,000 EUR, § 65 - purpose-related business)
• EStG (§ 3 Nr. 26 - instructor allowance, § 3 Nr. 26a - volunteer allowance)
• AFJD/agents/ (anonymized) - SSoT concept with sphere separation, pre-commit hooks

Source Topology and CDN Reference Links

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