The Controversial Application of the ne bis in idem Rule by the European Court of Human Rights in Respect of Tax Penalties

In this article, the authors analyse the ne bis in idem rule, in particular, the extent to which administrative sanctions are included within the scope of the rule and how a close connection between administrative and criminal proceedings arising out of the same set of facts can be established. Further, they comment on the manner in which the rule has been applied by the ECtHR in the context of tax penalties and the various issues that have arisen in this context.