The new criminal tax law

The Work offers a comprehensive and updated review of the regulatory and jurisprudential framework in the field of tax sanctions. The origins and diachronic evolution of the subject are analyzed, up to the current structure, marked by the expansion of European criminal law but also by new conceptions of penalty, enshrined in the recent revisions made by Legislative Decree 10 October 2022, n. 150, Legislative Decree 14 June 2024, n. 87 and the Consolidated Law on Administrative and Criminal Tax Sanctions passed with Legislative Decree 5 November 2024, n. 173. Due to the profound specialist experience of the Authors, the text is an indispensable tool for the competent exercise of professional and judicial activity in the field of punitive tax law as well as a valuable support for the scientific study of the subject also in view of the profitable preparation of university exams and public competitions.
The Authors have shared the awareness that the critical analysis of criminal tax law is a fundamental component of assistance in improving the tax system as a whole, as well as a guarantee instrument for the citizen and the community. The Work traces in depth the persistent restlessness, the intrinsic limits and the systematic and functional uncertainties of the regulatory framework in this area, reconstructing the interests that push to maximize tax revenue through the use of the sanctioning lever in order to solicit administrative compliance, with the risk of depressing the needs of general prevention in the fight against tax evasion. Furthermore, throughout the pages of the Volume, the reasons are revealed why supranational sources struggle to leave their mark on the paths of national legislation, sometimes transmitting to the latter the protective restlessness with respect to financial interests and handing down as a legacy original frameworks subjected to continuous tests of compatibility with constitutional and conventional guarantees.