Penal tax law
I represent my clients in criminal proceedings for tax fraud with the authorities for administrative fines and criminal proceedings and / or the tax investigation department of the Munich tax office with a focus on regulating the matter of the fiscal proceedings, i.e. by reaching a settlement or by means of a voluntary declaration.
I am frequently contacted by heirs who have received an inheritance with a “fiscal issue”. The background to this is when the testator has not met his or her fiscal obligations to the full extent. In such cases, if the heirs have knowledge of this, or should have had knowledge of this, they are subject to an obligation to report the matter. If this obligation is breached, it may lead to legal consequences for tax fraud. My office resolves such regular, complex cases for both the testator as well as the heirs, in both fiscal terms as well as in terms of the proceedings for tax fraud.
You can turn to me for comprehensive representation before the tax investigation department in the event of a suspected so-called domiciled company by the financial authorities. In such cases, which regularly occur in Switzerland and Liechtenstein, the tax office will try to attribute the results of the supposed letter-box company directly to the party involved from both a fiscal point of view as well as in terms of proceedings for tax fraud. Especially in such cases, that cannot be sufficiently investigated by the tax office due to the cross-border element, I am able to represent your interests particularly effectively.
Our clients repeatedly instruct us during ongoing company audits. Occasionally, suspicions of tax fraud are raised during an audit by the auditors, and they inform the party involved of this. This changes the legal status of the affected party, who will now require advice / representation in criminal proceedings for tax fraud.
I am also frequently instructed by tax advisers, who due to their vocational training only have limited experience and knowledge of representation in criminal proceedings for tax fraud. Furthermore, a simultaneous representation in fiscal matters and matters relating to criminal proceedings for tax fraud may not be compatible with the fiscal obligations of a tax advisor.
I have represented numerous clients in so-called banking procedures. This involves the transfer of money or securities to foreign countries, usually for the purposes of avoiding the amount withheld on savings tax from 1993.
I can also represent you in administrative proceedings (appeal proceedings) and at the financial courts.
In representing you, I focus on a mitigation of the fiscal consequences, also if criminal proceedings for tax fraud have been initiated or a voluntary declaration has been issued. Success in enforcing a lower rate of tax naturally has a direct effect on the proceedings for tax fraud.