About the complexity of the obligation of the Criminal Court to examine ex officio statute of limitations for criminal liability for tax fraud as the procedural obstacle

The commentary concerns one of the judgment of the Supreme Court, encompassing the analysis of the complexity of the statute of limitations for tax fraud, penalized in the Fiscal Penal Code. The Supreme Court’s conclusion should be shared that in the case of crimes related to tax frauds, the criminal court must also analyze circumstances outside the fiscal criminal law, related to the assessment of the effectiveness of the suspension of the statute of limitations for the tax liability