Complicity in Administrative Tax Offences in Italy

Giovanni Girelli


The principles of the system of criminal penalties inspire the legal construct of complicity in the administrative tax offence. However, the latter has relevant specifities that are particularly evident in two cases. First, when the violation ascribable to the taxpayer is also a consequence of the contribution of a tax advisor through his expertise. Second, when the tax offence is physically committed by an individual but in the interest of another natural or legal person. Furthermore, this paper underlines that the tax penalty system should be even more focused on the beneficiary of the tax offence rather on than its perpetrator, and in order to gain this aim, it is suggested to modify some rules today in force.


1 Complicity; 2 The specificity of the tax penalty system in the area of complicity; 3 Complicity of tax advisors; 4 The commission of the tax offence by an individual in the interest of a legal person.

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