Abstract
The article focuses on the interpretation of tax laws in the context of criminal and tax proceedings. It stems from the premise that although tax and criminal proceedings are independent, they overlap in practice in certain areas, leading to irreconcilable differences.
The aim of the article is to analyze these common points, clarify the causes of discrepancies, and assess whether they are in accordance with the law. A total of 9 combinations of tax and criminal proceedings have been identified.
For many of these combinations, it is highlighted that the difference in the outcome of the proceedings is related to the difference between the two proceedings. However, in one of the cases - the tax proceedings end without a finding and the criminal proceedings end with a conviction - the conclusion is drawn that it is most likely that there is misconduct by the tax administrator or the criminal authorities.