The ne bis in idem principle does apply to tax evasion and complicity in tax evasion. However, the Federal Court has just clarified that it does not prevent the director of a limited company that has been sanctioned for tax evasion from also being sanctioned as an accomplice, since the company and its director are distinct persons. It does not matter that the punishability of the legal entity depends on the fault of the same director (judgment 2C_872/2021 of 2.8.2022, intended for publication).
Sale of a shareholding of less than 10% from a participation of more than 10% – no entitlement to participation exemption
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27 Jul 2022 — Corporate taxation