A criminal tax case is basically a “proceeding like any other” – and can end with severe penalties for the accused or the accused. The particularly serious case of tax evasion (§ 370 paragraph 3 AO) is for example up to 10 years deprivation of liberty. At the same time, a self-disclosure pursuant to § 371 AO is already excluded if an amount of more than EUR 25,000 is evaded. In these cases, however, it is sometimes possible to discontinue the criminal tax proceedings under AO or StPO.

As the competent investigating authority of the public prosecutor's office, the tax office initiates criminal tax proceedings whenever there is a suspicion of a tax offence. First place has been occupied here for decades, how could it be otherwise, by tax evasion according to § 370 AO. A taxable person in accordance with § 370 (1) AO fulfills this fact if he