The Federal Supreme Court rulings 6B*90/2024 and 6B*93/2024 of February 3, 2025, raise fundamental questions regarding the criminal liability of tax advisors. The focus is on the requirements for perpetration of tax evasion and incitement thereto, as well as the distinction between permissible tax advice and criminal complicity. The rulings shed light on the different roles of in-house and external advisors and their significance for practice and the application of the law.
Position: Senior Advisor
Organization: Tax Partner AG
Email: luca.aspesi@taxpartner.ch
