Article 12 of the Decree establishes criminal liability for tax-related falsification. It stipulates that any person who knowingly falsifies a taxpayer's records or provides false statements impacting any declaration required under the Decree commits a punishable offence. The penalty upon conviction includes potential imprisonment for a term not exceeding two years, a fine, or both. The Article also holds the taxpayer accountable; if their records have been falsified or a false statement has been made concerning their declaration, the taxpayer is considered guilty of an offence and is liable to a fine, creating a distinct liability for the entity.