Die strafbefreiende Selbstanzeige gem. § 371 Abs. 1 AO im Rahmen von Mehrpersonenverhältnissen

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»Voluntary Disclosure Pursuant to Sec. 371 para. 1 German Tax Code in the Context of Perpetration and Participation« Gabriele L. Stark examines a variety of legal problems of the volutary disclosure pursuant to Sec. 371 para. 1 German Tax Code in the context of perpetration and participation. She concludes that the wording of the law ultimately excludes certain accomplices in the tax evasion and suggests a three-step-model for the determination of the content of the voluntary disclosure. She further focuses on the effects of a volutary disclosure that has solely been filed by a part of the accomplices.