The 2017 tax reform significantly strengthened the power of the Direct Tax Authorities to impose tax fines on taxpayers found in infringement of their tax obligations.
In this scope, the tax authorities mainly rely on provisions found in the General Tax Law of 22 May 1931 (Abgabenordnung, “AO“), which, depending on the violation found, provide for either administrative sanctions or criminal penalties that only judicial authorities can trigger.
The purpose of the new Circular LG – A n ° 67 of 28 July 2021 (the “Circular“) is to set guidelines for the tax offices to observe in case of application of these provisions.
Source Tiberghien
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