Critics and legal experts warn that the government's plan to curtail voluntary self-disclosure could have unintended negative consequences for both businesses and the state. Historically, voluntary disclosure has served as a practical instrument for taxpayers and companies to correct honest mistakes or identify and rectify tax risks in complex corporate structures. By removing the guarantee of immunity, the government may inadvertently discourage taxpayers from coming forward to report errors, as any disclosure could now trigger a criminal investigation regardless of the taxpayer's intent.
Legal professionals point out that this shift fundamentally changes the risk management landscape for businesses. In a world of dense and highly complex tax regulations, companies often rely on the ability to transparently correct errors to maintain compliance. If the 'way out' is removed, businesses may become more defensive, potentially leading to a decrease in the number of cases where hidden tax liabilities are voluntarily brought to light. This could result in fewer tax corrections and, ironically, less revenue for the state.
Furthermore, there are concerns regarding the administrative burden and the potential for over-regulation. Critics argue that the focus should remain on improving the efficiency of existing authorities rather than creating new, potentially bureaucratic structures. There is also skepticism about whether the projected revenue gains are realistic, given the costs associated with hiring 1,500 new specialists and implementing new electronic reporting systems. The risk, according to some observers, is that the government may be prioritizing political optics over a balanced, effective approach to tax administration.