Prevention, voluntary disclosure or assistance in criminal tax proceedings
Supporting our clients with regard to tax offences has gained particular importance in our consulting practice in recent years.
One of the main reasons is that the number of investigations in this area has increased significantly and that they are initiated at earlier stages. For example, more and more proceedings are being initiated against representatives of companies, local authorities, municipal companies and public benefit institutions during tax inspections – even with relatively low tax amounts. The question whether it is the person affected or the taxpayers themselves who benefit from the understatement is no longer relevant for the assessment of intent.
As lawyers and tax consultants, we share with you our extensive expertise on all issues related to tax law and procedure that may be the subject or consequence of criminal tax investigation proceedings. In individual cases we also work together with tax consultants from other law firms whose clients require corresponding advice.
Our consulting services:
- Comprehensive support in criminal tax investigations
- Preparation of a defence strategy in the event of an accusation under criminal tax law
- Preparation of expert opinions on tax and procedural law issues
- Preparation of supplementary declarations according to § 153 of the German Tax Code (AO)
- Preparation of voluntary disclosures with exemption from punishment in case of suspicion of tax evasion or fraudulent frivolous understatement of tax
- Negotiation of factual records in pending criminal proceedings concerning tax fraud
If it proves impossible to reach an agreement with the tax authorities and investigators and main proceedings are brought before a criminal court, we work closely together with lawyers specialising in criminal defence.
Regardless of a specific investigation, criminal risks should be avoided in advance. Therefore, we also support our clients in the development and implementation of a tax compliance management system which allows for proper fulfilment and documentation of tax obligations.