Decree-Law No. 34 of March 30, 2023, added in Article 23 a provision for the tax crimes of omission to pay VAT, omission to pay withholding taxes, and omission to pay security charges, which extends the cause of exemption from criminal liability to late payments made after the first instance judgment and results in the acquittal of the defendant on appeal.
If the defendant fully pays the tax authorities the due amount, the crime is extinguished and he is acquitted. Until now, the debt against the tax authorities could be paid off within the beginning of the trial in first degree. By this way, the person will have a longer time to provide, even by instalments, and, when convicted in first degree and appealing, may be acquitted, having paid off the debt.