Abstract: The particularities of tax law involves specificities of the subjects of law. The identification and delineation of concepts used in the tax law to designate the subjects of legal relationships generate impacts also in criminal law. De lege lata, we can identify specific categories: the taxpayer, the payer, the taxable person, the tax debtor, the third party. Defining these concepts and defining their legal content is the fundamental premise of criminal liability for tax evasion. In the same time, it is necessary to clearly trace the content of the obligations deriving from such qualities established by tax legislation. The intuitu personae contents of the tax liability is the source of the peculiarities of criminal responsibility. By the mechanism of these institutions, the tax framework supports and gives content to the criminalization standards. Special features must be verifiable if criminal participation is to be admitted.
Keywords: taxpayer, taxpayer, payer, legal, criminal partnership