Application Of Criminal Law As An Ultimum Remedium In Taxation Cases Post The Application Of Law Number 7 Of 2021 On Tax Regulations Harmonization

Countries that have stable economic strength can be classified as large countries. However, the existence of stable economic strength and prosperity depends on the level of public awareness in paying tax obligations. The challenge presented in this research is to figure out how criminal law is applied as an Ultimum Remedium in tax cases after the enactment of Law number 7 of 2021 on Tax Regulations Harmonization in 56 criminal verdicts in tax cases that occurred between 2022-2023. The research method used is literature study (Library Research) with a Normative Juridical perspective, and a qualitative analysis explained in a descriptive way The results of the research show that based on criminal verdicts in tax cases that have gone through judiciary and was decided from 2022 to 2023 after the enactment of Law number 7 of 2021 on Tax Regulations Harmonization, the panel of judges did not implement the Ultimum Remedium principle as a legal consideration in imposing sanctions criminal sentence for perpetrators of tax crimes. The principle of Ultimum Remedium contained in article 44B Law number 7 of 2021 on Tax Regulations Harmonization indicates that only fines should be applied as the final sentence without any prison/imprisonment sentence. Therefore, in the case of the fine not being paid within the specified time period; the perpetrator's assets must be confiscated or blocked. Therefore, state officials who exercise judicial power need to pay attention to aspects of justice being based on the aim of returning state losses that could be achieved in accordance with the aim of Ultimum Remedium principle in Law number 7 of 2021 on Tax Regulations Harmonization.