Recently we saw a lot of cases during our practice, where a harmless target audit (audit regarding the fulfillment of certain tax obligations) is followed by a criminal investigation initiated by the auditors. In other cases, the target audit is especially initiated by the tax authority to collect evidence for a future criminal procedure. The formerly typical case where after a tax audit a criminal procedure is initiated can still be seen, but not so often.
In this present article we try to give a big picture about the practice of the supreme court regarding fictitious invoices.
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