Abstract 

The development of corporate crime is in line with the development of the role of corporations in the cross-border economy, which has both positive and negative impacts, including corporate crimes, including tax crimes, which in Indonesia are regulated in Law Number 6 of 1983 concerning General Provisions and Tax Procedures, as amended by Law Number 11 of 2020 concerning Job Creation.

This research was conducted to examine the implementation of the theory of corporate criminal liability in tax crimes and to analyze the regulation governing corporate criminal liability in taxation offenses. The study found that the implementation of corporate criminal liability theory in tax crime cases has not been applied consistently, particularly when associated with the principle of legality, which has created challenges in law enforcement.