§ 219 Tax Act (StG) - Initiation of Proceedings

1. The criminal proceedings for tax evasion shall be initiated as soon as there are indications of tax evasion.

2. The initiation of criminal proceedings for tax evasion shall be communicated to the affected person in writing. They shall be given the opportunity to respond to the accusation made against them. They shall be informed of the right to refuse to testify and to cooperate.