«Nemo tenetur se ipsum accusare» im Steuerrecht

Nemo tenetur se ipsum accusare states that no one should be compelled to participate in their own criminal conviction against their will. This prevailing principle in criminal proceedings can come into conflict with the administrative law principle of participation in parallel proceedings. The work examines the intersection of these two principles in the field of tax law. Initially, the parallel proceedings are described independently of each other, and subsequently, an investigation is conducted to determine whether the applicable procedural regulations align with the case law of the European Court of Human Rights regarding Article 6 of the European Convention on Human Rights. This approach allows for the presentation of solutions that take into account both the Strasbourg case law and ensure a practical and efficient conduct of proceedings.