PENERAPAN HUKUM PIDANA SEBAGAI ULTIMUM REMEDIUM PADA KASUS PERPAJAKAN PASCA UNDANG -UNDANG NO. 7 TAHUN 2021 TENTANG HARMONISASI PERATURAN PERPAJAKAN N

Countries that have stable economic strength can be classified as large countries.However, the existence of stable economic strength and prosperity depends on thelevel of public awareness in paying their tax obligations. This research aims toexamine a number of 53 tax criminal decisions following the enactment of Law No.7 of 2021 concerning Harmonization of Tax Regulations in the 2022 tax year basedon the principle of ultimum remedium by looking at the theory associated with thisproblem, namely the theory of Justice. Where 35 of the decisions are tax criminaldecisions which will be resolved in 2022 and 18 of the decisions are tax criminaldecisions which will be resolved in 2023. This research uses a library researchmethod with a Normative Juridical Approach with a data analysis method usingqualitative analysis which is described in the following way. descriptive. Theformulation of the problem discussed is How to Analyze the Application ofCriminal Law as an Ultimum Remedium in Tax Cases Post Law No. 7 of 2021concerning Harmonization of Tax Regulations. The results of the research showthat based on the analysis of criminal decisions in tax cases that have gone throughthe judiciary and have been decided from 2022 to 2023 after Law No. 7 of 2021concerning Harmonization of Tax Regulations, the principle of ultimum remediumas the main sanction in punishment has not been fully implemented. convict in acriminal case in the field of taxation. The principle of ultimum remedium asintended in article 44B of Law N0.7 of 2021 concerning Harmonization of TaxRegulations indicates that only fines should be used as punishment for perpetratorsof tax crimes without any prison/imprisonment sentences. However, what willhappen during 2022-2023 is that there will still be many cases of tax crimes usingthe Primum Remedium principle where imprisonment/imprisonment is the mainpunishment.Keywords: Ultimum Remedium, Tax Crime, Tax Harmonization Law