СПОРЕДБЕН ПРЕГЛЕД НА ЕВРОПСКИТЕ КАЗНЕНИ ЗАКОНОДАВСТВА ВО СФЕРАТА НА ДАНОЧНАТА ЕВАЗИЈА
COMPARATIVE REVIEW OF THE EUROPEAN CRIMINAL LEGISLATION CONCERNING THE TAX EVASION

Summary/Abstract: Short review of the criminal legislation concerning the tax evasion, has been the point of the author’s interest in this article. According to the author, there are two legal models being practiced in the western countries concerning the tax evasion. The first system, the continental one, accepted by the French and German law, has some criminal law articles incorporated within the tax related legislation. The second one, accepted by the legal practice of Great Britain and the United States, deals with the tax related cases on the basis of precedent law. While French has been recognized as the most comprehensive legal system among the European countries concerning the tax evasion, the author underlines US regulation as the most sophisticated and consistent.

• Details
• Contents