Il ruolo del procedimento tributario nella determinazione dell'imposta evasa ai fini del giudizio penale

In the relationship between tax and criminal proceedings, characterized by perfect autonomy, the criminal court has to determine the measure of tax evasion in order to verify the relevance of the criminal conduct. However, the Supreme Court makes the autonomy between the two proceedings weaker, by giving to the administrative determinations primary effectiveness, although not binding, into the separate criminal proceeding for tax evasion. The result is a deep break of the autonomy between the two proceedings, symptomatic of the trend to abandon the "double-track" system in favor of one characterized by the increasing interference in tax matters between criminal and administrative aspects.