Section 379. Aggravated tax fraud

Aggravated tax fraud is punishable by a fine or imprisonment for a term not exceeding six years. In determining whether the tax fraud is aggravated, particular weight shall be given to whether it
  1. a.
    led to or may have led to the evasion of a considerable sum,
  2. b.
    was perpetrated in a manner which has to a significant degree made it difficult to discover,
  3. c.
    was committed on multiple occasions or over an extended period of time,
  4. d.
    was committed by multiple persons acting together or shows signs of planning or organisation,
  5. e.
    was perpetrated by abusing a position or relationship of trust, or
  6. f.
    was contributed to in the conduct of a business.
In determining whether the tax fraud is aggravated, multiple violations may be taken as a whole.
This section also applies even if there has been ignorance with regard to the factors which make the act aggravated, provided that the ignorance was grossly negligent.