LA RESPONSABILITÀ DEGLI ENTI PER REATI TRIBUTARI, TRA NE BIS IN IDEM E PRINCIPIO DI SPECIALITÀ

The extension of liability for tax crimes to legal persons, companies and entities poses problems of systematic coordination with respect to the relation- ship between administrative and criminal sanctions and the related proceedings. The article analyzes some critical issues related to the application of the specialty principle and ne bis in idem rule, and the related — and opposite — risks of both excess and inadequate sanctions.