Criminal tax proceedings have recently gained even more importance and attention. Investigations are taking place across borders and, as in the case of so-called cum/ex transactions, have a political dimension.
Due to the complexity and scope of the legal issues involved, even exemplary companies and individuals who are unaware of any wrongdoing can come under the spotlight. For example, choosing the wrong exit on arrival at the airport when transporting goods subject to declaration is enough to trigger a criminal tax investigation. A complex tax audit can also be accompanied by a criminal tax investigation..
A mere suspicion is enough to initiate a tax investigation, even if it later turns out that the suspicion was completely unfounded. Even inconsistent or incomplete information in a tax return can trigger an investigation by the tax enforcement authorities. Late filing of a tax return despite an estimated tax bill is increasingly leading to criminal tax proceedings if the tax authorities suspect that the taxpayer is trying to avoid higher taxation. Making a voluntary disclosure can be a means of avoiding criminal tax liability. However, it is not possible to make a valid voluntary disclosure if the tax authorities have already opened a criminal investigation or issued an audit order. For this reason, experienced criminal defence lawyers are needed at every stage of the proceedings who are both familiar with the tax laws and experienced in procedural law. Our team guarantees both. We often work together with the tax advisers and accountants who have already been appointed. Together we develop a solution to the problems.