Tax Crime Defense

Our practice in Criminal Tax Law is strategic, seamlessly integrated with our tax department and focused on protecting the liberty, assets and reputation of entrepreneurs, executives and corporations. We operate both in the early management of criminal risks arising from fiscal activities and in technical defense during investigations and criminal lawsuits, always with a precise, confidential approach tailored to the complexity of corporate operations.  

The area’s differentiator lies in the technical analysis that connects tax litigation to potential criminal repercussions, allowing us to anticipate scenarios, structure defense strategies and guide business decisions with legal certainty.  

Key Solutions:  

Administrative and Judicial Criminal Tax Litigation  

• Preventive counsel and risk mitigation.  

• Monitoring administrative tax procedures with potential criminal implications.  

• Representation in police investigations and criminal lawsuits involving tax crimes and related offenses throughout all stages of criminal prosecution—investigation, indictment, trial, judgment and appeals.  

• Strategic interlocution with the Public Prosecutor’s Office, specialized tax fraud police departments and fiscal oversight bodies.  

Criminal Tax Advisory   

• Technical legal opinions.  

• Strategic guidance.  

• Preventive support for corporate decision-making.  

• Monitoring legislative and regulatory updates.  

Criminal Tax Risk Management and Counsel  

• Preventive analysis of criminal risks linked to corporate activities.  

• Strategies for the extinguishment of punishability  and suspension of criminal prosecution (such as through tax installment programs or full payments).  

• Identification and classification of conducts potentially characterized as tax crimes.  

• Assessment of tax audits and administrative procedures with risks of criminal prosecution.  

• Advisory on corporate transactions, restructurings and M&A operations with potential criminal-tax impacts.  

• Guidance on voluntary disclosure of tax debts and mitigation of criminal liability.  

• Management and negotiation of criminal tax liabilities.