Problems of action in connection with blanket rules providing for criminal liability for tax violations

The article deals with the correlation of the legal content of the provisions of tax, administrative and criminal law establishing institute of responsibility for tax violations. Their provisions, while meeting the paradigm and internal logic of their area of law, when interacting with the provisions of other branches involved in the formation of this institution, do not form an efficient mechanism, adequate to the public danger and prevalence of tax violations, which would ensure compliance with the principles of certainty of punishment, equality before the law and court, justice. In particular, blanket criminal law prohibitions and the legal and technical methods used in their formation, in connection with the provisions of tax laws, allow for the penetration into criminal proceedings of additional grounds which are not typical of criminal law and which exclude criminal liability. At the same time, the temporal effects of criminal law are interrupted, obstacles arise which hinder the application of criminal concepts developed in the theory of criminal law, the basic principles of legal liability are violated. In this regard, the necessity of amendments to criminal and tax laws is justified.

налоговые деликты, институт ответственности за налоговые деликты, проблемы действия во времени бланкетных налоговых уголовно-правовых норм