O nouă perspectivă asupra conceptelor de „evaziune fiscală” și „fraudă fiscală”
A New Perspective on the Concepts of “Tax Avoidance” and “Tax Evasion”

Summary/Abstract: As far as definitions are concerned, the concepts of “tax avoidance” and “tax evasion” are not sufficiently determined in international tax law. There is a very thin red line between what is allowed and what is forbidden in terms of tax arrangements that might lead to a reduction of the taxpayers’ obligations. Based on this difficult choice of words, there is an even more difficult choice of procedures and sanctions to be applied for the taxpayers’ behaviour. The author refers to certain (recent) evolutions in the field, particularly with the Italian doctrine, that might lead to a more accurate interpretation of the concepts and a more fair treatment of taxpayers.

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