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GNOSIS 4/2006
The trans-national organizations are globalizing crime


In the last few years, the activities connected with organized crime are in continual expansion, thanks to the use of the new technologies and to the evident economic growth due to the constant increase of income derived from illicit commerce. One hears of the flourishing activity in the sectors of conventional and non-conventional arms traffic, human organ trafficking and the drug and prostitution market. The typical modus operandi of criminality provides, furthermore, that the illegal monies derived from crime activity are reinvested in legal activities which are often dummy societies, in this way impeding the judicial authorities to verify crimes and avoiding, at the same time, the application of prison sentences. Also the reports dealing with organized crime of the European Council underline the high index of danger from the new international organizations devoted to crime, fruit of agreements of cooperation between the different mafias, which have expanded their activities on a global scale, abandoning the regional dimensions which previously characterized them. In the article, the authors describe with thoroughness, the American and Italian experiences in the field of legislation directed to limit the phenomenon of the crime of tax evasion, which these criminal organizations incur in their illegal operations.

photo ansa

Organized crime on a trans-national scale

A “social-economic fact”
The dichotomy inherent in the words “organized crime” consists in placing side by side, by now, entered also into common slang, two mutually antagonistic juridical constructions: one founded on the business association structure which seems typical of lawful systems (1) and the other, conversely, on an illegal fact or act.
This is to say: the crime, insofar as it is in violation of the law-making precept, cannot organize itself, structure itself in the same way as an association with statute, top management, subordinates and objectives to reach, but refers exclusively to the individual, isolated insomuch as placed in never-ending antagonism with the rest of society.
History, unfortunately, denies this assumption, since the global scenarios disclose the evidence of continual contraposition between criminal organizations and legislative-judicial power; between mafia matters, camorra and special laws, coercive actions, which have come into being to confront the basic culture which has triggered off the aberrant phenomena of contiguity to political power and pollution of the institutions, in general.
Nevertheless, if an historical excursus is made, important associative phenomena can be found which oppose real and proper associations, therefore, more organized and structured subjects among them, to the constituted Order, expressions of the social community.The fight of the mafia associations perpetrated against State organizations for centuries is an example, as well as the long series of special laws issued with the sole purpose of creating a juridical instrument finalized towards the precise identification of the organized framework within the criminal phenomena, and its eradication from society.
The said organizations, in every way similar in their internal structure to the associations of the economy, also produce and maximize their profits.Such activity, which denotes the economic nature of the criminal association, foresees the possibility of investing money and puts in motion a series of criminal acts which will result in the production of illicit proceeds (2) .
This economic character of the criminality will be assisted by the new form of investment which transcends the traditional forms of the market based on the exchange of goods and services, that is to say, the finance market. The finance market, essentially consisting in the employment and movement, in the virtual sense, no longer in the physical sense, of very large sums of money, both at the national and international level, becomes fertile ground for the employment of illicit funds.
In every way faithful to the Latin aphorism pecunia non olet, money coming from illicit activities is invested just as lawfully earned money is invested.
The Union itself bases its own economic prosperity on monetary factors, and on the informatics technology which allows a rapid trans-national employment, all to the advantage of the stronger economies and to the detriment of those which, only very recently, have come upon the global scene.
The investments of a finance company nature become increasingly prevailing factors in the so-called “liberal” economies or with the “market system”, where the specific weight assumed by the movement of capital becomes the preferred source of money-making.
However, if we want to go back to the real origin of the capital employed by the stock exchanges of the great industrialized nations, we shall discover that as a remunerative source, it also has the recycling of money from illicit provenance.
Recycling is the activity which par excellence singles out the economic factor of the criminal activities of the organizations which have taken hold in the Western superpowers, democratic and free-trade. Therefore, we are speaking of thriving activities concentrated in the sectors of: the sale of arms – conventional and non-conventional (chemical and bacteriological); the trade in human organs; the drug market; environmental pollution by the concealment of waste material of various origins and nature.
Furthermore, if we examined the effect of the above mentioned activities on the economic market, we should merely find that same is dependent almost entirely on the economic course of the criminal activities above mentioned (3) .
In fact, the influence that the arms market has on the entire industrial world cannot be ignored: since it is placed as pioneer in the advanced research for the continual elaboration of military means and weapons of the highest precision and efficiency, it determines an acceleration in the field of technological research to such an extent as to influence every other economic sector.
A more direct verification of what has been said can be had when we go to analyze the quantum in economic terms deriving from the presence on the market of companies, obviously quoted on the Stock Exchange and structured in holdings with leader companies and associates, of criminal matrix.
It is roughly calculated that the drug market furnishes proceeds equal to 300-400 billion dollars, regularly churned into legal circuits of the finance market and in continual rise, thanks, above all, to the new sector of synthetic drugs for which production the criminal organizations have succeeded in lowering the costs to the point of being able to produce the drugs directly in the principle consumer countries (Spain, Italy, Belgium) (4) .

Swiss national bank - Berna

Alongside these two major bastions of the criminal market is the prostitution traded, which in some states, in primis, Italy, reaches a turnover equal to 1% of PIL of the industrial sector of textiles or clothing. In addition, the trade in human organs is a market in evolution with staggering profits (it is understood that a kidney can have a value of $3,000, a liver circa $8,000 and a heart can reach a figure of $20,000)
Furthermore, the continual replacement of the ‘pieces’ would seem to be guaranteed in the sales contract by an efficient medical health apparatus incorporated within the trans-national criminal organizations.

Evolution of the criminal
economic ‘associationism’

While, in the past, the forms of organized crime were regionalized, i.e. regions are the single world areas as defined by the major theoreticians of geopolitics (Europe, East Europe, Latin America, the USA, the ex-USSR), today, the operator of the criminal organizations has become global. So much so that the last Report presented by the United Nations shows, to a disturbing extent, the prevailing presence on the criminal scene of the trans-national organizations even more dangerous than the mafia phenomena which convulsed America in the first decades of the 20th Century.
Also the Reports on organized crime of the European Council show a high index of danger from the new international organizations given to crime: a danger due to the increased importance of the economic factor which is at the base of these same activities. The leitmotif of the international criminal is to reach the maximum profit with the minimum risk.
Consequently, these organizations, renamed OCT, “Trans-national Criminal Organizations”, have developed particular characteristics, such as operating on a world scale and no longer on a local one; the presence within the organizations of a sub-division of managerial tasks directed to researching the maximum profit in the criminal sector of interest, as well as the investment of the proceeds in legitimate financial circuits, which makes investigation by the judicial bodies extremely difficult (5) .
The fact appears alarming, therefore, that at an international level, experts of the FMI and of the World Bank have joined in defining the presence of criminal organizations in the industrial and financial world as a real irruption, citing as an example, the Thailand financial crisis, where the circulating money of illicit origin quantitatively surpassed the State budget.
Many expert world famous jurists have joined in launching the alarm in relation to the aggregation phenomenon of the different mafias which, in a perfect spirit of cooperation and solidarity, have started to tighten alliances and agreements directed to rationalize their contemporary presence on the markets which are still not fully exploited, and on those emerging ones.
Beside these alliances of a strategic-diplomatic kind, we can put alongside of them the criminal activities created by the rising terrorist organizations which need funds to carry out their projects.
Therefore, we have before us organizations which can be characterized as real and proper businesses of crime, which in the spirit of the economy of profit are in continual evolution and in search of new forms of criminal investment and illegal activities, from drug trafficking to infant pornography, passing to informatics and environmental crimes, and all with highly qualified personnel and avant-garde technology.

The taxation of illicit proceeds

The cycle of a criminal activity connected to a criminal type of situation of economic matrix, tends to begin and conclude through the evidence of income flows characterizing the finality itself of the illicit activity.
In fact, the acquisition of the means useful for the accomplishment of the criminal conduct, the procurement of the sources on the part of the criminal organizations (especially as they seem to be historically rooted in the territory), depends strictly on the search of financial means to sustain the structure of their criminal associates and to guarantee the survival itself of the criminal groups.
Likewise, the final objective of the modern criminal associations, lies in the possibility of reintroducing into the economy the price, the profit of the crime, so as to feed the ‘lawful’ channels which overhang the undergrowth of the criminal organizations, with top management, as already said, often unknown to themselves, even if it is only a front.
These illegal activities are actuated, in the majority of cases, through societies with juridical character (Spa or Srl); instruments through which the real centres of interest are able to hide their identity, by fitting into the social plateaux other societies (with the ‘mechanism of the Chinese box’ or acquiring stocks or shares – always in the majority – on the part of companies, preferably established in countries with favoured tax conditions) (6) or persons with no criminal record, proposed with the sole scope of showing an apparent formal regularity.
The cases of the utilization of trust companies to which are conferred mandates for capital sharing in credit institutes or for the constitution of holding companies are not infrequently used.
To the above reflections can be added another, similarly verifiable by all the social observers or rather, that for which the penalties provided for by the legal system, considerably concern the constriction of the individual liberty of those who have acted on behalf of the criminal organizations, that is, the application of sentences of detention.
All the investigative effort or, at least, the major part of them are directed towards the finding and acquisition of the proof of the common crime in order to hand over the responsible parties to Justice: the investigations are often long and complex. At times, the aspects which could better verify the dimensions of the offence and result in a more efficient handling are often ‘pushed to the back seat’; i.e. the financial flows, the proceeds and the traceability of investments which, subsequently, go to feed the ‘lawful’ activities.
It is extremely rare that these huge volumes of money are recovered, which because of the illicit fact, they have been subtracted from the availability of the “having right” or much more simply, they can be called “the fruit of the crime” (7) .

The American Experience
The first excellent arrest for tax evasion

In the USA, in the 30’s, a heated debate opened on taxing income originating from illicit activities and it concluded with the approval of a series of purposely designed regulations provided for (and still provide for) heavy penalties, in direct measure to the crime, and constrictive to personal liberty.
The occasion, in that epoch, was extremely appetizing for the FBI men: to attempt a venture in which they had never before succeeded, to consign to Justice one of the most wanted men, declared public enemy number one of the city of Chicago, Al Capone (8) .

Al Capone

Al Capone was one of the most powerful and ruthless gangsters of the 30’s. He took advantage of the American Prohibition to take over the control of the secret traffic of alcohol, expanding his illicit activities to include also gambling and other remunerative sectors.
He soon aligned ‘legal’ activities with his illicit ones. In fact, a good part of the proceeds were turned into legal commerce; on the Stock Exchange and in other forms of lawful activities. Operating in this way, distinguishing the management of the bookkeeping, the Boss could count on very large cash flows of coverage.
Strong in the support of the new laws which permitted the taxing of proceeds deriving from illicit activities, the FBI organized a team of hand-picked agents (9) to give the chase to Al Capone. They put every single one of his activities through the sieve. He used participating companies of citizens who were above suspicion and who possessed spotless criminal records, nominees and accounting managed in code. The FBI men succeeded in finding one accounting document bearing his name and unequivocal reference to reinvested illicit proceeds. Thus, the tax evasion of Al Capone was demonstrated. It was enough to trap him and to draft an extremely ample accusatory plan, which amounted to a good 23 indictment counts.
For these charges, after some trial vicissitudes (10) , Al Capone was condemned to 10 years in prison and was given a very heavy fine.
He served the first part of his sentence in the Atlanta Penitentiary and then in Alcatraz.
Still today, the American tax penal laws are among the most rigid of the Western juridical panorama. Above all, “the certainty of the punishment” is assured for the tax evaders. In fact, about two thirds of the citizens who serve the most severe sentences are authors of illegal acts connected to the world of finance (11) .

The tax penalty regulations of Italy
Brief notes

With the 7th January, 1929 Law, No. 4, the Italian Legislator introduced a series of principles into the juridical panorama which have constituted a source of inspiration in the matter for a good half century (12) .
In this article we shall deal only with the principle which introduced the “preliminary tributary” or rather – the tortuous route imposed on the tax controversies (in the cases of tax evasion) which, before being judged in a criminal court, had to be defined; or rather – get through all the levels of taxation judgement (Provincial Commission, Regional, Central and Supreme Court).
All these ‘laborious steps’ resulted in excessive and exhausting delays and constituted a ‘filter’ between the administrative procedure of verification and criminal action.
In other words, the tax evasion could be defined as a criminal offence only after definitive confirmation at the administrative levels (years past from the verification of the illicit to the criminal hearing).
With the intent to innovate normative instruments able to cope with the discouraging economic-fiscal criminal context, our legislator, in 1982, identified a series of anti-juridical actions constituting crime and thus criminally liable for punitive sanctions, as outlined in the Law 7.8. 1982, No. 516 (13) .
The Law 516 brought to an end the “preliminary tributary”, permitting the definition criminal action, without the definitive verification of the evasion. But almost all of the kinds of crimes contemplated in the Law 516 were of an infringement nature (14) .
They were the so-called “danger” crimes, the verification of which determined the hinging of criminal proceedings that very often terminated with clement sentences, when it was not possible to have recourse to the “settlement out of court” (15) .
In 1993 (tangentopoli - the corrupt economic and power system founded on the request and payment of bribes – the subsequent scandal and consequent trials): to stem the spread of the economic crime and also to recuperate for the tax office, at least a part of the profit/product of the illicit activities, a law was passed which included in the system, a particularly controversial regulation, which aimed to strike illegal enrichment through the tracing to taxation of the proceeds deriving from an illicit civil, criminal or administrative fact or act (16) .
The motivations at the root of this regulation are to be found in the constant absence of goods (wealth) which could be used again by the investigated or condemned subjects of economic crimes, and who were not recipients of really efficient conservative or preventive measures.
It concerns a regulation freed from the claim of tax imposition: refer to the combined provision of Articles 1 and 53 of the Constitution (17) by reason of the impossibility of evaluating the contribution capacity of wealth obtained by illicit means.
It is, therefore, a legislative provision in clear punitive spirit, which aims to strike, also from the fiscal standpoint, illicit enrichment (18) . In fact, all the following cases are considered taxable: the income of usury, the income of businesses deriving from criminal activities and income of work or business deriving from illicit activities (19) .
Also the production of income of autonomous work or of business deriving from illicit activities exercised in the absence of a qualification required by the fiscal legislation, such as the lack of registration in the professional album, the lack of the required professional qualifications for the execution of an activity, the lack of a commercial license or other administrative authorization: in synthesis, the violation of obligatory rules or of the provisions of collective negotiation (20) .
In the year 2000, the tributary criminal normative panorama was further innovated, introducing with the decree law no. 74, seven previsions of well-defined crime and the principle of “damage” scaling the penalty to be inflicted to the conduct. Now, criminal cases in point are indexed which provide for the specific fraudulent misinterpretation of the evasion and consent more incisive investigation activities, such as telephonic interceptions and the application of detention measures.
The violations of mere form are no longer criminally punishable.
With the decree Law 4.7.20006, No. 223 (21) new cases in point of crimes directly connected with fiscal evasion (22) have been identified and obligatory accounting has been introduced for commercial traders and professionals who tend to limit the use of cash money.
In fact, these subjects, from now on, must possess accounts (bank and postal) dedicated to the activity, used, prevalently, for incurred expenses and for the obligated showing of payments received in the exercise of the professional function.
Remuneration must be received exclusively through means of traceable financial instruments (23) and not in cash form, except for sums inferior to one hundred euro (24) .
Our legislator, with the cited measure, places particular attention on the circulation of cash money, beginning by limiting its use in professional relations. This constitutes a remarkable step ahead for the monitoring of the financial flows which, as previously mentioned, is fundamental for the re-construction of the economic activities which generated them.
Always on the subject of tax evasion as an element constituting crime, excellent arrests have been made, also in Italy. There is the case of the well-known Neapolitan actress who was charged, in 1973, for tax evasion on a taxable amount of 112 million lire. Four years later, she was sentenced to a period of one month in prison, (but in the meantime, the actress and her family had re-located to Switzerland and then to the USA). But, in 1982, to avoid an embarrassing exile, she returned to Italy to serve her sentence. After only 18 days, she was released.
The prison where the actress was detained became a destination of pilgrimage for actors, actresses, journalists, free-lance photographers, ordinary people and, listen well, also refreshment stalls which sold drinks, sandwiches and various gadgets, far into the night. There were even those who declared indignation over the treatment that the State had reserved for this illustrious actress who had contributed to making Italy known throughout the world.
In subsequent years, up to today, other excellent people have been caught in the net of the revenue authorities, getting away with only a fine, even when the amount due was high.
Many have resorted to the stratagem of acquiring citizenship in the generous principality of Monaco, but they have been identified by the Inland Revenue and reported for fiscal offences connected with evasion. Among these are: a famous tenor, a champion of the Alpine skiing world, singers, actors, composers and, a famous violinist.
To conclude, there is the excellent Argentinean footballer, who played for Naples for years, and to whom the Supreme Court of Appeal levied a “fine” of over 31 million Euro. For him also the joke... as soon as he set foot in Italy, they confiscated two watches and the “fee” for his participation in a television show.
Yes, but ...Al Capone, in America, was sentenced and served his prison term. Here, perhaps, for the same crimes, what with deferments, remissions, amnesties, pardons and various emendations, he certainly would not have suffered the same fate.

Principality of Monaco

(1) “The criminologist’s interest in organized crime is mainly directed towards two areas of study:
1- the observation of the single members, understood as criminals who often have peculiarities due to inclusion within the sub-culture of the organization;
2- the organizing analysis, which aims at underlining the dynamics and structure (and their evolution in time) of the delinquent group.
With regard to the first area of study, the criminologist must obtain, above all, fact-finding instruments able to point out the influence of the organizing structure on the personality and actions of the subject, without forgetting, however, his residual capacity which determines his own behaviour. Instead, with regard to the organizing dimension, a possible methodological and conceptual solution is represented by the employment of interpretive paradigms borrowed from other branches of the social sciences, particularly from the area of the psycho-sociology of work and organizations, considering, therefore, the complex criminal groups as organizations with an end to the production and accumulation of wealth, broadly speaking, distinguished (but only as variable) by aspects of illegality. This approach, therefore, considers the criminal structures as systems finalized to the production-accumulation of wealth, employing in certain phases, illegal technology and input (resources) and allowing the obtainment of vast and tested interpretive paradigms.” Text taken from M. Strano, Manual of Clinical Criminology, see Editions Florence, 2003
(2) “…economic motives are often at the base of criminal behaviour oriented towards profit. Criminal behaviour, excluding that which is provoked by personality disturbances or emotional irrational impulses, obeys the rule of rationality: that is, the criminal is sensitive to both the benefits and the estimated costs of his behaviour, and many of these costs belong to the area of the risk of punishment. The micro-economic theory can explain certain examples of criminal behaviour and help to diminish the amount by contributing to the formation of policies which reduce the benefits and increase the costs. This is the first relation between economy and criminality. E. Savon, in Economy & Criminality. Pg.97.
(3) “… the development in criminal operation in always more complex organized forms, constantly directed towards illegal enrichment, requires that the juridical order, in the criminal area, protect the economy in a more direct and precise way, as a category of lawful goods protected against criminality, in the same way as for the constitutionally guaranteed natural rights and principle liberties, with the lawful penalties against the invasive and damaging behaviour of the private rights, recognized by the legal system or rather, with the protection of the figure of the State, of the Public Administration, the Justice Administration..”, L. Carta, N. Altiero, “The Mafia infiltration into the real economy”, (Review of the Revenue Guard – Guardia di Finanza).
(4) The drug business in Italy, today, is around 13 billion Euro of which 4-5 billion concerns the synthetic drug market, the production of which has literally exploded within the arc of the last three years. 90% of the production and trafficking of the drug is controlled by the great criminal organizations and there is an ever increasing relation between the drug market and the prostitution market which, by itself, according to recent estimation, has a volume of business which goes beyond 30 thousand billion. Furthermore, the major traffic of drugs is also connected to the increase of clandestine immigration of extra-community immigrants used by the criminal organizations, both indigenous and foreign, for the carrying of different types of drugs and their sale in the small and great urban areas”. Source: CIRM Investigation commissioned by FIPE and SILB.
(5) “… In the same way as business associations become internationalized to maximize earnings and minimize costs, so the criminal organizations tend to cross the borders of the single States to search for major opportunities for gain on the international markets; at the same time they avoid the risk of being intercepted and destroyed, with the arrest and confiscation of the wealth of their members. The international ambit allows the optimization of opportunity and risk factor, either because much illegal traffic is becoming more and more internationalized (drugs and stolen cars, to give just two examples), or because police and criminal justice activities still run along national lines and progress with much more difficulty and slowness along international ones. Business opportunities and law enforcement risk are the two principle determining factors of this internationalization process of the criminal organizations – today as in the past – for the individual stories of the different criminal groups. If there is still a certain vagueness on what could be included in the definition of “trans-national criminality”, there is, instead, an agreement on which could be considered the most important criminal organization at a world level. Among these, proceeding from the West towards the East, the Columbian cartels, the Nigerian criminal organizations, the Sicilian Mafia and, more in general, the Italian criminal organizations, the Russian criminal organizations, the Chinese Triads and the Japanese Yakuza. Some of these groups have very ancient traditions, like the original Asiatic organizations and the Sicilian Mafia. Others are relatively more recent, like the Columbian cartels and the Russian Mafia, and still others have come to international attention only in the last few years, like the Nigerian groups…”. U. Savona in Organized Criminality. Page 428.
(6) These countries are analytically listed in the so-called BLACK LIST published with D.M. 23.1.2002 and subsequent modifications and integrations.
(7) “From the second half of the last century, instead, the criminal phenomenon had reached such a level as to suffocate the economy on which it had grafted, and from being a simple parasite, it became a tumour which, in its gravity, became irreconcilable with the very reality on which it lived. Clearly, the role of the Institutions has always been to protect the economy and market from said criminal phenomenon. Notwithstanding, for some decades, in the more evolved economies (sophisticated in the field of capital, world markets and globalization, the results of the fight are no longer considerable..” The Taxation of Illicit Proceeds, Marco Parrivecchio, in the Review of the Superior School of Economy and Finance, ANNO III, No. 5 – May, 2006.
(8) Alphonse Capone, born in 1899, from Italian emigrants in America, died in 1947 in his villa in Florida, from a heart attack.
(9) On the orders of Frank Wilson, a team of federal agents from the Tax Bureau, headed by Captain Elliot Ness.
(10) Al Capone tried and succeeded in corrupting the entire peoples’ jury, but at the last moment, just before the hearing, Judge Wilkerson, with a stratagem, had the whole jury substituted with that of another trial hearing.
(11) In the last five years, with reference to 2005, there have been over 11,000 (to be precise) 11,475 American tax-payers believed by the Federal Courts to be promoters of, responsible or co-responsible for a large number of tax offences. Among the tax-payers proved guilty, 9,581 (around 83%) were transferred swiftly from the Court Room to behind the bars of numerous fiscal penitentiaries, and each one of the 9,581 tax-payers imprisoned for tax evasion reasons has served 30 months in prison. Source: Internal Revenue Agency.
(12) Principles of fixity, ultra-activity and preliminary tributary.
(13) This law has, in some aspects innovated, and in other aspects, worsened the applicable punishments for tax evaders, so much so as to be renamed the law on the “handcuffs on the evaders”.
(14) ... apart from the art. 3 and 4 which provided for criminal behaviour for grave facts, distinguished by a particular difficulty of the proof.
(15) It was the Article 162 bis c.p. which “threw a rescue line to evaders”.
(16) Such regulation is Article 14, para. 4, of the Law 24.12.1993, No. 537
(17) Article 1. “Italy is a democratic republic, founded on work…”
Article 53. “Everyone is required to participate in public expenses, according to their contribution capacity …”
(18) Article 14, para 4, of the Law 24.122.1993, No. 537 reads: “in the income categories of which Art.6., para 1, of the only text of the taxation on income, approved with Decree PR 22.12.1986, No. 917, must be understood included, if classifiable, the proceeds deriving from facts, acts or activities qualified as illicit civil, criminal or administrative, if not already subjected to seizure or criminal confiscation. The relative incomes are determined according to the disposition regarding each category”.
(19) In the past, the disposition of which Art. 14, para. 4, of the Law 537/1993, has been object of divergent applications and interpretations, with particular reference to the innovative and interpretive nature and to the possibility of the incorporation in the income categories of the financial provenance deriving from crimes.
(20) It is useful to represent that there does not exist, as conditions of legal action, the presence of a criminal sentence which reassumes the gravity of the conduct, this insomuch as (Supreme Court, No. 15567 of 2000) it was affirmed that to be able to establish whether proceeds of an illicit nature is incorporable or not, into one of the recognized categories, it is necessary to identify the source of income and compare it with the positive data, in its objectivity, leaving apart the gravity of ascertained anti-juridical behaviour, with an end to verifying if the same can come within the situation assumed by the legislator as a general source.
(21) Converted into Law No. 248/2006
(22) The omitted payment of IVA (VAT) (and unlawful compensation) resulting from the presented annual declaration, for an amount exceeding 50,000 Euro. The same penalty applies to the tax substitutes who do not pay the certified deductions to the substitutes.
(23)Non-transferable cheques or bank drafts, bank transfers, credit cards, bancomat etc.,
(24) This limit will come into force from 1.7.2008. Until the 30.6.2007, the limit below which the fees can be received in cash money is equal to 1,000 Euro. From the 1.7.2007 to 30.6.2008, the limit is 500 Euro.