Law regarding fiscal offenses

The law regarding fiscal offenses is characterized by the increasingly advanced tightening of legislation and adjudication in recent years. This is accompanied by increased investigation activities of tax offices and prosecution. On the other hand, the possibilities of voluntary disclosure exempting from punishment were restricted. Increasingly, tax structures whose legality is in doubt are also investigated by criminal means. Investigation proceedings under the law regarding fiscal offenses can also work as a means of exerting pressure so as to enforce settlement in the underlying taxation procedure.

We have wide experience in the defense against charges under the law regarding fiscal offenses. This concerns the charges of the incorrect and incomplete declarations of private and business income just as proceedings in the area of VAT evasion and other types of tax; for example, we acted and act in so-called cum/ex proceedings and proceedings concerning “VAT carousels”. Our lawyers advise and defend individuals as well as companies and banks. They are familiar with the peculiarities of fiscal criminal proceedings, in particular the interlocking of the fiscal criminal proceedings and the taxation procedure running in parallel. Therefore, we work closely with tax advisors and auditors, where required also internationally. Furthermore, we support our clients in the filing of voluntary disclosures exempting from punishment.