Criminal Law

We know that criminal tax matters not only present legal challenges, but also entail personal and emotional burdens. Our experienced criminal tax law team will accompany you on this journey and offer you the support you need.

VAT law and customs law are often at the heart of internationally active companies and groups. Imagine you run a successful company. Suddenly you receive an order for a special VAT audit due to irregularities in your VAT returns. Or you are confronted with allegations of customs evasion in the context of international trade. The uncertainty and concern about possible consequences and damage to the good reputation of your company can be overwhelming in such a situation.

This is where we come in. Our experts, who have already successfully resolved countless many similar cases, will thoroughly analyse your situation and negotiate with the tax authorities in a targeted manner. We use customised strategies to defend your rights and work to ensure that the proceedings are discontinued and your good reputation is restored. With our support, you can concentrate on the essentials again - the success of your company.

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[{"title":"Triangular Transactions in Focus: General Court Rejects German Tax Authority\u2019s View","nid":"5418","body":"In VAT practice, a well-known risk persists: Member States interpret the conditions for the simplification of triangular transactions differently. Some only apply the rule if exactly three parties are involved. The German tax administration is more flexible: more than three parties may participate \u2013 but the simplification applies only to the last three taxable persons in the chain (sec. 25b para. 2 of the German Administrative VAT Guidelines). Neither restriction can be found in the wording of the EU VAT Directive. Are these limitations even permissible? The General Court makes it clear in\u2026","field_datum":"08.12.2025\n","field_newsletter":"VAT Newsletter 48\/2025"},{"title":"ECJ: scope of necessary checks and attribution of knowledge of tax evasion in supply chains","nid":"405","body":"Time and again, the tax authorities have denied input VAT deductions to taxable persons because they should have known, had they exercised due diligence, that they were participating in tax evasion with their supplies. In this context, the ECJ has now ruled that taxable persons are not required to carry out complex and comprehensive checks on their business partners, such as those that can normally only be performed by the tax administration (judgment of 01.12.2022 \u2013 C-512\/21 \u2013 Aquila Part Prod Com). At the same time, however, the ECJ held that taxable persons must accept responsibility for\u2026","field_datum":"09.12.2022\n","field_newsletter":"VAT Newsletter 51\/2022"},{"title":"Self-disclosure: Prohibition of compensation and surcharge","nid":"5251","body":"The effectiveness of a voluntary self-disclosure depends on the payment of a surcharge; even from evasion amounts of as little as EUR 25,000. The legislature has, as from 1 January 2015, once again increased the amount to be paid. According to the fiscal authorities, the surcharge is to be paid, in full, by each accomplice. It is irrelevant whether the accomplice has gained a personal benefit from the act of evasion. Furthermore, VAT liability and input VAT deduction are not offset for the purposes of the assessment of the surcharge. For this reason, a heavy penalty might be due, even if\u2026","field_datum":"16.04.2015\n","field_newsletter":"VAT Newsletter 13\/2015"}]

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[{"title":"Criminal statute of limitations","nid":"5148","view_node":"\/en\/criminal-statute-limitations"},{"title":"Reckless tax evasion pursuant to Section 378 of the German Fiscal Code (AO)","nid":"5150","view_node":"\/en\/reckless-tax-evasion-pursuant-section-378-german-fiscal-code-ao"},{"title":"Sections 30 and 130 of the Act on Regulatory Offences (OWiG) - corporate liability for tax offences","nid":"5328","view_node":"\/en\/sections-30-and-130-act-regulatory-offences-owig-corporate-liability-tax-offences"},{"title":"Tax evasion pursuant to sec. 370 of the German Fiscal Code (AO)","nid":"5149","view_node":"\/en\/tax-evasion-pursuant-sec-370-german-fiscal-code-ao"}]

Our services

Advice on criminal tax law matters

We develop an individual procedural strategy and support you with any questions from a criminal law and tax law perspective.

Defense in criminal tax and customs law investigations (criminal proceedings/fine proceedings)

We stand by your side as defense lawyers – from developing the defense strategy until the closing of the proceedings.

Preventive advice to avoid criminal tax law risks

We help you to identify risks at an early stage and avoid them by taking appropriate measures.

Preparation and submission of voluntary disclosures and corrective declarations

We provide you with discreet and comprehensive support in preparing voluntary disclosures and correcting incorrect declarations.

Representation before tax authorities and law enforcement agencies

We represent your interests when dealing with tax authorities and law enforcement agencies.

Investigations

We provide immediate support to your company during tax investigation searches (on-site or by phone). We also train your employees proactively to be prepared for search situations, create behavioral guidelines, and implement corresponding processes for your company.