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28/07/2025Even If You Win the Tax Case, the Tax Office Looks at the “Directive”MoreAt the lowest floor of the hierarchy of norms, working almost underground, there is a document; the Tax Offices Operations Directive. It is the directive, not the court judgment, that gets applied.
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20/07/2025The Judicial Recess; Should Justice Stop for 40 Days?MoreEvery year the judiciary is officially on holiday between 20 July and 31 August; January is an unofficial interim period. In an age where digitalisation has advanced this far, we should reconsider the necessity of the judicial recess.
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21/04/2025The Presumption of Innocence and Pending Files on UYAPMoreIn cases under Article 359 of the Tax Procedure Law, criminal judges focus on the question “does he have other files on UYAP?” despite a favourable expert report and a prosecutor’s plea for acquittal. A file that has not become final cannot be a
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18/04/2025The Tax War with Artificial Intelligence BeginsMoreA prospective client told me he had drafted his replies to a draft tax audit report with ChatGPT. Taxpayers now consult not only their accountant but also artificial intelligence.
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08/04/2025The Last Paragraph of Article 367 Was Annulled; the Solution Lies in Article 218/1 of the Code of Criminal ProcedureMoreWhether an invoice is false is a legal characterisation made by the tax court. Where the criminal court has been informed that an action is pending before the tax court, it must treat that action as a preliminary question.
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16/11/2024Could We Say “Tax Fraud” Instead of “Tax Evasion Offence”?MoreAlmost all the acts in Article 359 of the Tax Procedure Law contain the element of deceit. The offence with which tax evasion should be compared is fraud, not the other forgery offences.