In ongoing company audits
During a company audit, it may happen that the auditor arrives at the conclusion of suspected tax evasion.
The tax officer is then obligated to inform the affected party of their suspicion. This changes the legal status of the affected party, who is now in the position of being the accused party in criminal proceedings.
This has a serious effect on fiscal obligations. The taxable party is then no longer obliged to cooperate with accounting for the large part of the fiscal issue, insofar as the party accounts for this itself.
Also in such a case, it must be ensured that only the tax that has actually been accrued is assessed. The lower the resulting subsequent payments are, the more favourable the proceedings for tax fraud will be.