Tax regulations – as a rule – provide for protection against fiscal penal liability in the event of successful submission of a correction to the tax return. This follows from Art. 16a § 1 of the Fiscal Penal Code (KKS), according to which the perpetrator of a prohibited act concerning the submission of a declaration is not subject to punishment, if after its commission a legally effective correction of the declaration was submitted to the tax authority and the amount of depletion of public law receivables was immediately paid. Therefore, taxpayers submitting corrections to declarations are often convinced that in such a situation there is no risk related to liability under the provisions of the Penal Code.
Source MDDP
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