Criminal tax proceedings have not only gained in importance in the public perception in recent years — in their various forms, they also make up a significant part of my work as a defence lawyer for companies, executives and private individuals.
Following a wave of VAT carousel proceedings, the consequences of the so-called ‘PanamaPapers’ and the still ongoing criminal investigation into ‘cum/ex’ transactions, further developments are now raising new questions: such as the debate about the possible criminal liability of cum/cum transactions, criminal tax law issues surrounding crypto gains, and the taxation of ‘digital nomads’ and influencers.
In addition to these dynamics, legislative measures and increasingly restrictive case law are also placing high demands on the defence in criminal tax cases. For example, the requirements for an effective voluntary disclosure have been tightened several times in recent years and the statute of limitations for particularly serious cases of tax evasion has been significantly extended. In addition, there have been relevant decisions on concurrent offences, the prohibition of compensation, the confiscation of the proceeds of crime and errors of fact.
Criminal tax allegations can quickly threaten the livelihoods of those affected – this is precisely where it is crucial to consider possible tax and economic consequences. I can help you to understand complex tax and criminal law issues at an early stage, assess risks realistically and develop viable defence strategies.
