Criminal responsibility of taxpayers and other tax debtors

The author reviews questions which are related to criminal responsibility of taxpayers and other tax debtors, at least for two reasons: firstly, the expert literature does not give answers to some very important questions and secondly, the same questions are currently imposed by the newly amended solutions in the tax legislation. The author establishes that the quantity of criminal responsibility of taxpayers and other tax debtors had risen, but, at the same time, not its quality. Precisely, disproportion in certain segments is the topic of this article. The author concludes that various aspects and tax issues are well covered in the legislation and therefore, draws our attention to those questions which are not and how legal solutions can be improved. The legal nature and character of tax evasion leads us to a conclusion that the tax crime is criminal act sui generis in comparison with the criminal act of fraud. It is also to be concluded that in the tax legislation, tax crimes are legally and technically very good determined, in their substance and in relation of their perpetrator, legal entities, responsible persons, natural persons and other persons possibly involved in this type of responsibility.