Self-disclosure

A special feature of criminal tax law is the voluntary disclosure that exempts you from punishment. There is no comparable norm in general criminal law. Section 371 AO enables the offender to submit a voluntary report before the tax offense is discovered. The legal consequence of the complaint is impunity. The evaded or reduced taxes must be paid later.
The incorrect or omitted information must be corrected or subsequently submitted. The self-disclosure must be submitted by the tax authorities before the offense is discovered. The reason for the impunity is to secure the tax claim. Tax sources that have not yet been discovered are to be tapped, and complicated and lengthy criminal proceedings to be avoided.

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