Analisis Konsep Ultimum Remidium Terhadap Rekonstruksi Sistem Pemidanaan dalam Undang-Undang Perpajakan

Implementation of criminal sanctions in the Act No. 28 Year 2007 on General Rules Taxation, give rise to legal issues conceptual level. That Tax Law, is a part State Administration requiring forceful measures for taxpayers, especially Taxable Entrepreneur, which principle form criminalization administrative behavior. Criminal through legality, wants norm setting strict and obviously legislation, it appears be broken Taxation. Parameters crime taxation limited only by elements negligence intentional, with implementation under based discretion competent institution. Thus, gave transactional behavior practical Therefore, ultimum remedium, becomes extremely important avoid use arbitrary discretion.