Criminal Tax Law

The communication and cooperation of fiscal authorities within Germany and across borders has become more intertwined. The confidentiality of banking in so called tax havens has weakened considerably. The statute of limitations for fiscal crimes has been tightened dramatically. The boundaries to criminal offences are becoming more and more difficult to define.


In the meantime, countries such as Lichtenstein and Switzerland have agreed to provide their client-related banking information to the German fiscal investigative authorities. The confidentiality of banking as we know is slowly but surely eroding.


As a result of the closer networking between fiscal and investigative authorities, more and more taxpayers are being subjected to prosecution for tax related offenses. Pensioners, wich have not thought to have been legally obligated to file tax returns, are being tracked and found through data interchange. Apart from payment of taxes for prior years, fines and imprisonment can be imminent.


We advise our clients on all issues regarding fiscal offences; from a tax point of view this comprises the preparation of a voluntary report to the tax authorities of false or incomplete tax returns, subsequent taxation proceedings, and the submission of the required tax returns.


Additional benefits:

  • Preparation of past incomplete tax returns within the realms of the precautionary voluntary declaration to avoid punishment
  • Representation in proceedings with tax investigation authorities and/or in court (assisted by our associated lawyers)
  • Presence during searches