The regularisation of criminal tax evasion

Abstract

This article analyses, basically from a procedural point of view, the various legal consequences of regularising a tax evasion situation that, due to the amount of tax evaded, could be considered a criminal offence. The article first considers the tax and criminal consequences of filing a tax return late when more than €120,000 is owed in tax. It then looks at the varying effects on the criminal liability of the party that commits the tax evasion, depending on when it is regularised. Finally, we consider the effects on both criminal sentencing and the potential civil liability arising from the criminal offence when regularisation does not exonerate the party from liability.