Gli incerti confini tra evasione e abuso: profili fiscali e penali

[Autom. eng. transl.] The distinction between abusive conduct (subject to administrative sanctions) and evasion (criminally relevant) is complex. Despite the attempts of the legislator to establish a borderline between the two concepts, the system still appears to have little protection towards the taxpayer, in the absence of reference regulatory criteria. From a perspective perspective, a clearer regulatory systematization of the criminally relevant area would then be appropriate with respect to what integrates the extremes of the abuse, even in the face of guidelines of the jurisprudence of legitimacy that are not always univocal.