Unless Articles 14 to 16 of the Federal Act of 22 March 19741on Administrative Criminal Law (ACLA) apply, a fine not exceeding 250,000 francs shall be imposed on any person who wilfully, for their own benefit or the benefit of another person:
a. commits tax evasion by:
1. failing to fulfil their obligation to levy the one-off payment, final withholding tax or tax finality payment, or
2. failing to transfer the one-off payments, final withholding taxes or tax finality payments to the FTA;
b. breaches their disclosure obligations in accordance with Article 6 or 16.
Where such an offence is committed through negligence, a fine not exceeding 100,000 francs shall be imposed.