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This study aims to analyze the implementation of the ultimum remedium principle on a case of tax crime in Indonesia based on the legal certainty principle in law enforcement. This research is descriptive, applying the case study method and using secondary data in documentary materials and library research. This study concludes that the tax auditor initially put forward criminal tax law enforcement rather than administrative tax law enforcement. The audit process does not reflect the legal certainty principle for taxpayers. The postponed examination became the preliminary evidence examination until the defendants' prosecution did not reflect the ultimum remedium principle's implementation. That ultimum remedium principle stipulates in Article 44B of the KUP Law (Law No. 28 of 2007).

The Ultimum Remedium Principle and Its Implementation on Tax Crime in Indonesia: a Case Study