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Federal Constitutional Court: Tax-CD in the case of Liechtenstein LGT recyclable

For a search warrant from the AG Bochum in a criminal tax proceedings, which was based on a tax-CD in the case of Liechtenstein LGT, put the person concerned - after exhausting the legal process - a constitutional complaint. This was unsuccessful.

The resolution text is not necessarily conclusive: The Federal Constitutional Court be justified in his non-acceptance decision, which was today given a lot of effort, why the law is so clear and obvious that no decision on the merits would require. Therefore, the Constitutional Court did not accept the constitutional complaint for decision.

are now at least two interpretations of the verdict: first

The Federal Constitutional Court to demonstrate that it believes that the legal position was so clear that a decision was unwarranted.
second Or the Constitutional Court a decision on the merits was more or less circumnavigate elegant.

Everyone likes to form his own opinion on this. The firm is KONLUS comment on this decision in the AO-Accountants (No. 1 / 2011).

In case of further tax purchased by NRW-CD (va Credit Suisse data) remains to be seen a constitutional complaint. Whether the case is similar, depends also on the operational procedures of the sale, which are to be clarified in the file.

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Lecture held by UBS for Swiss assistance

For today invited the UBS Basel a lecture "DBA Switzerland-Germany & Outlook control negotiations" in the "3rd floor (floor for German customers).

showed a nutshell, the following points that were previously in the media not so clearly stated: first

There are two agreements, namely the new DBA with the so-called major OECD information clause and a still to be negotiated Zusatzabkommen.

2. Das Zusatzabkommen soll u.a. Regelungen für die steuerliche Behandlung der Vergangenheit und der Zukunft vorsehen. Wichtig war der Hinweis, dass ggf. eine Schweizer Volksabstimmung über das Zustimmungsgesetz zu diesem Abkommen erforderlich wird. Dies ist dann der Fall, wenn ein bestimmtes Kontigent an Unterschriften für eine solche Volksabstimmung durch eine Volksinititative eingeholt wird. Sollte eine Volksabstimmung notwendig werden, so wird das Zusatzabkommen - die Zustimmung des Volkes unterstellt - frühestens im Jahr 2014 in Kraft treten können (sonst: frühestens 2012).

3. Die Schweiz leistet nach dem neuen DBA auch ohne einen Anfangsverdacht einer Steuerhinterziehung bzw. eines sog. Steuerbetruges Amtshilfe, wenn es sich um Informationen handelt, die sich im Besitz von Banken befinden.

Fazit: Sämtliche Überlegungen zu einem Zusatzabkommen (Abgeltungsteuer, ggf. Strafbefreiung für die Vergangenheit) helfen Mandanten, die zeitnah eine Entscheidung treffen wollen, nicht weiter. Der Zeithorizont bis 2014 ist für Mandanten deutlich zu lang . Daher sollten sich Mandanten auf der Basis des bisherigen Rechts und aktuell vor dem Hintergrund der noch im Dezember 2010 geplanten Gesetzesänderung zur Selbstanzeige beraten lassen.

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Where a Court ruling an old tax bill repealed?

Beim EuGH ist vermehrt das deutsche Steuerrecht auf dem Prüfstand.

Mandanten fragen daher often: If a favorable Court ruling to that old tax notices are ineffective?

The BFH 16.09.2010 ruled on this controversial question (PR 57/09): No are final, the correction rules of § § 172 ff AO. exception: There was an objection lodged on time.

It is therefore recommended - if not Vorläufigkeitsvermerk exists under § 165 AO - at least at higher levels of taxation to object in order to benefit later if necessary by a Court ruling. The objection procedure rest until then operation of law, when a procedure is pending at the ECJ, § 363 para 2 AO

KONLUS The firm will also discuss the verdict in the trade press.

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revision of tax reporting yourself

The draft the new regulations currently circulating. For this design, the following points: first

There will be no surcharge (in addition to interest) of 5%.

second Even ads that are pending delivery of the law brought out, even with only partial Nacherklärung so far (!) For fiscal impunity. Thus, the Federal Court Judgement of 20.05.2010 (abolition of the partial self-disclosure, see Beyer, AO-StB 2010, 195) does not apply.

third Even ads that after the announcement of the Act be given shall be effective only if "clean sweep" is made. "MotoGP Champion" means that all time periods and tax types that are vejährt not criminal, must be nacherklärt.

4th If the self-disclosure within the meaning of point 3 is incomplete or incorrect, but this is only harmful if the person knew or this "a reasonable appraisal of the situation had expected" (§ 371 para 2, No. 3 AO-Draft) . will be crucial if so far simple negligence hurt in practice ("must-know" means gemäßt § 122 para 2 BGB negligence).

5th In future, a self-ad already announced a test arrangement is ineffective (previously only appearance at the auditor). If necessary. alive the possibility of self-display after completion of the audit back to (unclear).

still subject to the above points have not yet. On 08/12/2010, the Federal Cabinet discussed the draft.

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income tax return: fill out line 108 "business abroad?

The forms for income tax for 2009 includes the cover sheet following question (line 108):

? Talk to sustainable business relationships with financial institutions abroad Yes / No "

How should this question be answered?

There is no case law on this issue. My View, the question inadmissible for the following reasons: first

With the proper filling of forms and OFF CAPE fulfilled his civil duty to cooperate.

second The broad wording of the question in line 108 is not the wording of the provision of § 90 para 2 clause covered 3 AO. AO § 90 governs the participation requirement explicitly only for so-called tax havens. According to Ministry of Finance at the moment there is no so-called tax havens for the purposes of this standard, because this would be published in a list of the BMF. This list is empty at the time, according to BMF.

third § 90 para 2 clause 3 AO shall not apply until 2010 and therefore can not be applied relate to the past for 2009.


Recommendation:

Therefore, the question - if the plants have been completed and KAP OFF - I think neither yea nor nay be answered. Crosses as a dutiful citizen the "yes" when he as a credit card has a foreign financial company, he alone therefore - into the "test screen" of the tax office and must answer inquiries - unjustified. Apart from a credit card should not "sustainable" business reasons as defined by § 90 paragraph 2 sentence 3 AO.

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identification measures in the tax proceedings?

§ 81b Code of Criminal Procedure allows prosecutors and auxiliary officers to carry out the so-called Straverfahren identification measures.

This also applies in criminal tax proceedings, unless it is a Bagatellangelegenheit.

What does this mean?

The person concerned must appear at the police, for example to allow his fingerprints to be stored or photos are taken of his face.

must appear to the person concerned?

This must be verified by a lawyer. The obligation to appear may be made if the person accused and the measure "necessary". The measure is necessary only if such a likelihood of confusion (for example, has accused the look-alike brothers) and business partners are as Witnesses are questioned whether they have negotiated with the accused.

Tip: The measure should, if it takes place, are still disputed as a precaution on the appropriate form.

What happens if the deadline is missed?

Dan threatens to forcibly show.

What can be done about the charge?

A lawyer can determine whether a court application or a complaint can be considered. If a lawyer turned on, it can possibly ask for postponement for consideration.

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seizure of accounting records for Accountants

The LG Eating has made it clear that the seizure of accounting records may be seized in the office of an accountant (this must also apply to a lawyer) only limited circumstances :

accounting records of an accused who are the tax advisors, as long seizure-free according to § 97 para 1 Code of Criminal Procedure, as it the Tax act, ie a maximum to the generation and release of the respective accounts (LG Essen, Judgement of 12.08.2009, 56 Q 7 / 09).

Note:

This view is, however, by the tax police agencies in their work rules (AStBV) divided not so explicitly. There it is ultimately left to the discretion of the Tax investigators found, the legal opinion he represents.

If the tax adviser accused himself, the privilege is seizure pursuant to § 97 Code of Criminal Procedure does not apply to files that concern him as a suspect.