Tax Criminal Law

Tax Criminal Law – Your Defense Against Allegations of Tax Offenses


As a law firm specialized in criminal and tax law, we represent companies, entrepreneurs, and private individuals nationwide in all areas of tax criminal law. Whether accused of tax evasion, tax concealment, or smuggling, our experienced defense attorneys stand by your side at every stage of the investigation and criminal proceedings — with legal precision and strategic foresight.

With clear strategy, in‑depth tax law expertise, and many years of experience, we protect your interests — in person at our offices in Göttingen, Kassel, or Hannover, or flexibly and nationwide via video consultation.

What Is Tax Criminal Law?

Tax criminal law covers all legal provisions that penalize violations of tax obligations. The key criminal offenses include:

OffenseLegal BasisTypical Parties Involved
Tax Evasion§ 370 Fiscal Code (AO)Individuals, Entrepreneurs
Smuggling (commercial/gang-based)§ 373 AOImporters, Logistics Companies
Receiving Stolen Tax Goods§ 374 AOThird-party Beneficiaries
Customs Breach§ 372 AOTraders, Import/Export Companies


The most common charge in tax criminal law is tax evasion under § 370 AO. A person commits tax evasion by knowingly providing false information or omitting required disclosures to the tax authorities in order to reduce their tax burden or unlawfully obtain financial advantages.

Why Is Tax Criminal Law So Complex?

Two legal frameworks intersect in tax criminal law:

  • The Fiscal Code (AO) for tax procedures
  • The Code of Criminal Procedure (StPO) for criminal proceedings

This overlap creates significant tension – e.g., between the right to remain silent in criminal law and the duty to cooperate in tax law. That’s why a strategic defense approach is essential.

Tax Criminal Law: Key Risks You Should Be Aware Of

A tax criminal investigation can have far‑reaching consequences for your professional and personal life:

  • Imprisonment: In severe cases, imprisonment without suspension on probation may be imposed.
  • Asset Forfeiture: The state can seize or recover assets obtained through tax‑related conduct — often on a broad basis.
  • Reputational Damage: Public investigations or media coverage can lead to lasting professional harm.
  • Professional Sanctions: For tax advisers, managing directors, doctors, or attorneys, even an investigation can endanger professional licenses.
  • Exclusion from Public Contracts: For businesses, such sanctions can be economically devastating.

A prompt, discreet, and specialized defense is therefore essential.

Why You Need a Specialized Defense Attorney Now

A tax criminal proceeding differs fundamentally from an ordinary criminal case. It requires:

  • extensive knowledge of both criminal and tax law
  • a clear understanding of complex tax transactions and accounting processes
  • experience in dealing with investigators, tax authorities, and the fiscal police
  • a strategic approach regarding access to case files and available defense options

The line between a simple mistake in a tax return and criminal tax evasion is often crossed unintentionally — yet investigations may follow quickly, posing severe financial and personal risks. Authorities frequently assume intentional conduct, even when none exists.

Early consultation with a specialized tax criminal defense attorney is therefore crucial — both to prevent conflicts and to defend effectively in ongoing proceedings. We often work closely with your tax advisers to ensure a coordinated and efficient defense.

Our Services – Your Individual Defense Strategy

We develop a tailored defense strategy for every case. Depending on the circumstances, we assess both the legal and fiscal aspects and pursue the most favorable outcome for you. Our goals include:

  • Termination of proceedings (e.g., for lack of sufficient suspicion under § 170 (2) StPO)
  • Avoidance of public trial (e.g., through communication with authorities or by settlement order)
  • Mitigation of penalties or avoidance of entries in criminal records

We also focus on preventing secondary consequences such as:

  • Disqualification as managing director (§ 6 GmbHG)
  • Professional bans or disciplinary proceedings
  • Reputational harm or corruption register entries

Typical Cases in Tax Criminal Law

In practice, the following scenarios frequently lead to investigations:

  • Tax evasion in corporate settings
  • Undeclared foreign accounts or cryptocurrency trading
  • Incorrect or incomplete VAT pre‑filings
  • Conflicts during tax audits or fiscal investigations
  • Irregularities in estate or succession planning

Who we represent

We provide discreet and skilled representation for:

  • Entrepreneurs and self‑employed professionals
  • Managing directors and executives
  • Tax advisers and accountants
  • Investors and asset managers
  • Private individuals with foreign income or digital assets

Frequently Asked Questions (FAQ)

False or incomplete statements in tax filings or failing to notify the tax office – aiming to reduce tax liability.

If tax evasion is suspected — for example, as a result of a tax audit, anonymous tip, data matching, or report from a third party — the tax authorities will typically initiate criminal proceedings. In many cases, the investigation is taken over by the tax investigation unit (“Steuerfahndung”). Possible investigative measures include:

  • Review of case files by the Department for Fines and Criminal Tax Matters (BuStra)
  • Searches of business premises or private homes
  • Seizure of documents and IT systems
  • Interviews or interrogations of involved persons
  • Coordination with the public prosecutor’s office

Important: Even in the early investigative phase, authorities can take action that may result in serious financial or personal consequences. That’s why it is critical to seek legal counsel at an early stage — to help shape the course of proceedings and prevent escalation.

When facing criminal charges related to tax matters, having a specialized defense is crucial. Make sure your attorney:

  • has in-depth expertise in both criminal law and tax law,
  • has practical experience dealing with tax investigation units, tax offices, and public prosecutors,
  • understands and can realistically assess the options of voluntary disclosure or case dismissal.

Our law firm offers exactly this combination of qualifications: Certified specialists in criminal and tax law, as well as certified tax crime advisors (DAA), with years of experience in defending complex tax-related cases. We advise you discreetly, strategically, and with one clear goal: to prevent damage before it occurs.

Seek legal advice immediately. In many cases, a voluntary disclosure can still exempt you from prosecution.

No – criminal liability requires intent. However, gross negligence can lead to tax surcharges or administrative fines.

Your trusted expert for tax criminal law in Germany

Contact Us Now

We offer you tailored and competent defense – with top-tier expertise in tax criminal law. Representing clients across Germany.


Schedule a free initial consultation today.