Tax Criminal Law

Owing to its increasing Europeanisation, German tax law has become so complex that even legal experts find it a major challenge to master. The resulting potential for both factual and legal misunderstandings means that even “harmless” tax audits often lead to criminal investigations. In the worst case, even someone who has paid all their taxes then has to answer for being an alleged tax evader. Because it is immediately enforceable and supposedly backed by criminal sanctions, the tax authorities’ “different” legal view carries great force.

In order to counter the momentum and interplay of both proceedings effectively, it is essential here, too, to confront the authorities and courts proactively with a suitable antithesis. Often, the first step is to prevent immediately enforceable additional tax assessments or provisional asset freezing measures from effectively pre-empting the outcome of the tax and/or tax criminal proceedings. We then ensure that our antithesis is heard in both the tax and the tax criminal proceedings.