On para-penal evolution of administrative tax sanctions on the example of additional tax liability and default interests (Polish and Italian comparative analysis)

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In recent decades administrative tax penalties in Italy evolved in para-penal direction. This means they have acquired some of the principles and features typical for criminal law. In the meantime administrative tax penalties in Poland were developed significantly and, so, doubts on mutual relation of criminal and administrative sanctions emerged. Comparative analysis in terms of the phenomenon noted in Italy might help to solve this problem. So far, the Polish administrative tax penalties have not evolved in para-penal direction as Italian ones. Yet, there are signs of similar tendencies.