Legislation on tax crimes includes peculiarities to reinforce the position of tax authorities and grant the omitted payment of taxes. Is it possible for the Tax Authorities to report tax crimes after a tax audit is completed without finding any evidence of a crime? Article 197 bis.2 of the General Regulation on Tax Audits empowered tax authorities to assess crimes «at any moment». The Spanish Supreme Court has declared this rule void (with a vocal dissenting opinion). In our view, the provision clashed against the rules of the General Tax Act. Currently, tax authorities must report tax crimes when they receive new proofs (Article 262 Criminal Procedure Act) but cannot bring into motion a new audit. It is doubtful whether the taxpayer can ad...
The reform of the Criminal Code passed by Organic Law 7/2012, of 27 December, has modified the relat...
Law 7/2012 has made very substantial changes to the legal regulations governing the preventative mea...
El trabajo estudia de forma global el contenido y los efectos de la preclusividad de las resolucione...
This article aims to examine the key points regarding changes introduced in the regulation of the ta...
In a sentence of conviction for a crime against the Public Treasury, a penalty of deprivation of lib...
The purpose of this paper is to explain why the current model of relationship between tax proceeding...
In the field of taxation, everyone knows how important the regulation of the tax crime contained in ...
Spanish Supreme Court of Justice has determined that the Spanish tax administration incurred in an u...
The goal of this paper is to study the legal regime when the Tax Administration, before establishing...
After the incorporation of the administrative infringement in the supposed of conflict in the applic...
The planned reform of the General Tax Law, following the 2012 reform of the Spanish Criminal Code (f...
The main target of the article is to analyze the evolution of the «fifth year problem», which was bo...
El trabajo analiza la Sentencia del Tribunal Supremo 1246/2019, de 25 de septiembre, la cual anuló e...
The present paper analyzes the question concerning the possibility that the Public Treasury practice...
Does the tax offense constitute prior criminal activity for the purposes of money laundering offense...
The reform of the Criminal Code passed by Organic Law 7/2012, of 27 December, has modified the relat...
Law 7/2012 has made very substantial changes to the legal regulations governing the preventative mea...
El trabajo estudia de forma global el contenido y los efectos de la preclusividad de las resolucione...
This article aims to examine the key points regarding changes introduced in the regulation of the ta...
In a sentence of conviction for a crime against the Public Treasury, a penalty of deprivation of lib...
The purpose of this paper is to explain why the current model of relationship between tax proceeding...
In the field of taxation, everyone knows how important the regulation of the tax crime contained in ...
Spanish Supreme Court of Justice has determined that the Spanish tax administration incurred in an u...
The goal of this paper is to study the legal regime when the Tax Administration, before establishing...
After the incorporation of the administrative infringement in the supposed of conflict in the applic...
The planned reform of the General Tax Law, following the 2012 reform of the Spanish Criminal Code (f...
The main target of the article is to analyze the evolution of the «fifth year problem», which was bo...
El trabajo analiza la Sentencia del Tribunal Supremo 1246/2019, de 25 de septiembre, la cual anuló e...
The present paper analyzes the question concerning the possibility that the Public Treasury practice...
Does the tax offense constitute prior criminal activity for the purposes of money laundering offense...
The reform of the Criminal Code passed by Organic Law 7/2012, of 27 December, has modified the relat...
Law 7/2012 has made very substantial changes to the legal regulations governing the preventative mea...
El trabajo estudia de forma global el contenido y los efectos de la preclusividad de las resolucione...