Pursuant to Article 201(4) of the amended Criminal Law, the special provision on the conditional exemption from the criminal liability shall apply to the tax evasion act done before the implementation of the Criminal Law Amendment VII and not determined after the implementation hereof, and a first offender of tax evasion who has made up all the underpaid taxes, paid the fines and served an administrative penalty upon a recovery notice from tax authorities may not be subject to criminal liabilities.