In the administrative and criminal handling section, the Supreme Court affirms the dividing line: violations of tax obligations that are administrative in nature are handled administratively and subject to administrative sanctions, while those that constitute tax crimes are handled criminally and subject to criminal sanctions. However, PERMA emphasizes that administrative and criminal handling is not a mandatory sequence of processes—meaning that it does not automatically have to go through the administrative route first before criminal handling is carried out.

PERMA also provides an important limit to the realm of pre-trial. The handling of tax crimes is described as including preliminary evidence examination/investigation, handling of criminal acts that are known immediately, investigation, prosecution, examination in court, to the execution of the decision. In this context, the Supreme Court affirms that all preliminary evidence examination activities are not included in the pre-trial authority.

Regarding pre-trial (Article 8), PERMA provides guidelines for judges: pre-trial is adjudicated by the district court in the jurisdiction of the investigator, or the position of the public prosecutor for applications related to the legality or illegality of termination of prosecution. PERMA also stipulates that if the pre-trial applicant is a suspect who is on the wanted list (DPO), the judge shall issue a decision that the pre-trial application cannot be accepted.

In terms of the capacity of the judicial apparatus, PERMA encourages the chairman of the court to appoint judges who have attended technical education and training in the field of taxation to examine pre-trial and the merits of tax criminal cases. If there are no judges in the court who have attended such training, the chairman or deputy chairman of the court may be appointed to examine the case.

In the chapter on procedural law, PERMA contains regulations regarding asset security and evidence. The series of provisions includes blocking, confiscation for evidence, and confiscation for recovery of losses to state revenue, accompanied by a mechanism for the role of the public prosecutor in applying for certain determinations to the judge when the evidentiary requirements are met.

PERMA also opens up space for payment of principal tax and administrative sanctions in the phases of the examination process. For defendants who make repayments after the reading of the charges and before the verdict, PERMA regulates different verdict consequences for individuals and corporations: the judge may declare the defendant guilty with the imposition of a fine calculated from the payments that have been made, and for certain scenarios individuals may be declared guilty without the imposition of imprisonment. Repayment is also a consideration for the judge in determining the length of imprisonment and the amount of the fine.