The criminal tax proceeding is a proceeding before the law enforcement authorities and courts which concerns a tax offence within the meaning of the Tax Code (AO). At the same time, § 385 (1) AO refers to the provisions of the StGB and StPO applicable to other criminal proceedings. Therefore, in particular, the punishment, the basis of which is the gravity of the guilt of the perpetrator, plays an important role. Because the court has a sometimes considerable room for interpretation here.

The eighth part of the tax code regulates the tax offences and the associated criminal proceedings, which the tax authority and the public prosecutor operate jointly. According to the following standards, the following penalties exist for individual tax offences: