The legal framework and German Supreme Court rulings in the area of criminal tax law and criminal customs law have become considerably stricter in recent years. The regulations for a voluntary self-disclosure exempting from prosecution have been limited; indictments and thus criminal proceedings have become more frequent due to the Supreme Court's directive for a stricter sanctioning of criminal tax offenses. Furthermore, international cooperation between authorities has expanded - also with regard to former offshore tax havens. As a result of these stricter conditions, companies are obliged to use and demonstrate even more rigorous control mechanisms, for example in the area of tax compliance. The different procedural regulations and defence options in administrative tax proceedings and in criminal tax proceedings must be taken into account at all times.

FS-PP Berlin defends and advises its clients in these matters applying the highest level of expertise. This includes close cooperation with tax advisors and auditors as well as the handling of transnational mandates. The tension between the duty to cooperate under tax law and the right of defence under criminal law must be proficiently resolved and any defence is to be tailored to the individual client's needs.



Dr. David Albrecht

Dr. Viktor Volkmann