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.

In what cases and under which circumstances may we apply for the mitigation or the remission of our tax debt? What is the duration of payment of tax debt in instalments? What does exactly the postponement of payment mean in case of tax debt? What kind of data do we have to provide and what do we have to certify for the tax authority to decide over our payment facilitation request?

In the following part of this present article we answer the above questions and discuss the basic rules of the so called equity procedures (tax debt mitigation, remission, instalment payment procedure).

Testimony, declaration in front of the tax authority.

What is the difference if we make a declaration as a client or as a witness?