Abstract: The present study raises a dynamic and evolutionary problem, that of the competition of fiscal and criminal procedures in the fight against fiscal illicit. The keystone is of course the concern to respect the principle of non bis in idem, especially when both proceedings tend to apply sanctions or issue debt securities for the same damage. The study takes up recent benchmarks in the jurisprudence of the European Court of Human Rights and the Court of Justice of the European Union.

Keywords : tax evasion ; fiscal sanction ; penal sanction.