Reati tributari, sequestro preventivo e attualità delle esigenze cautelari

The discipline of the seizure on equivalent amount appears to be reconsidered because of the fact that that the object of the confiscation (the profit) and of the tax liability (the unpaid tax) coincide, so as to result, in terms of penalties, a overly punitive system.
So, if the slope of the seizure the taxpayer could not pay the debt, in case of condemnation, the sanction could be even more pervasive investing the tax area, criminal and confiscatory, clearly in contradiction with the principle of proportionality and reasonableness of the penalty