Abstract

Guilt in law is inextricably linked with the onset of responsibility, while having two forms negligence or direct intent. Guilt in modern law is commonly understood as a mental (intellectual and volitional) attitude to ones act and its consequences. Meanwhile, the tax authorities are required to determine the guilt in tax legal relations based on the results of tax audits within the framework of desk and field inspections. Meanwhile, a logical question remains which criteria of guilt are applicable in tax audits, in the absence of such in tax legislation, and which tools will indicate direct and indirect signs of guilt. The research methodology includes a systematic approach, a historical and comparative method, and a method of deduction. The purpose of the work will be proposals for the development of criteria for assessing the taxpayers guilt in the application of tax liability.

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