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Crime > Age of criminal responsibility (notes): Countries Compared

DEFINITION: Additional information, qualifications, exceptions and notes on the age of criminal responsibility stat, which indicates the age at which a person is no longer excluded from criminal liability.
COUNTRY DESCRIPTION
Argentina Official age of criminal responsibility; from age 16, children's actions are subject to juvenile legal proceedings.
Australia Age of criminal responsibility in Australia . Rebuttable presumption of incapacity of committing crime: under 14.
Brazil Majority age is 18; but from age 12 children's actions are subject to juvenile legal proceedings and sanctions.
China Absolute minimum for acts that constitute the following crimes: homicide, wounding resulting in death, rape, robbery, arson, explosion, planting of toxic substances and trafficking in dangerous drugs. The minimum age for other crimes are 16. In Hong Kong, the minimum age is 10 and in Macau, 16.
Colombia Official age of criminal responsibility; from age 12, children's actions are subject to juvenile legal proceedings.
Croatia 14 for all crimes under the general provisions of the Criminal Code; special provisions may apply for some crimes up to the age 21
Germany Minors between 14 and 18 years are sentenced by juvenile justice. An adult between 18 and 21 years may still be sentenced by juvenile justice if mental matureness is not existing.
Hungary 12 for premeditated homicide, voluntary manslaughter and bodily harm leading to death or resulting in life-threatening injuries; 14 for other crimes.
Iran Age 9 for girls, 15 for boys
Italy Juvenile judiciary system for offenders aged between 14 and 18; separate juvenile jails. Full criminal responsibility from age 18.
New Zealand 10 years for murder and manslaughter, 12 for crimes with a maximum imprisonment of fourteen years or more, 14 for all other offences.
Peru Official age of criminal responsibility; from age 12, children's actions are subject to juvenile legal proceedings.
Philippines A child fifteen years of age or under at the time of the commission of the offense shall be exempt from criminal liability. However, the child shall be subjected to an intervention program. A child above fifteen years but below eighteen years of age shall likewise be exempt from criminal liability and be subjected to an intervention program, unless he/she has acted with discernment. Discernment means the mental capacity to understand the difference between right and wrong and its consequences.
Portugal Currently being studied the possibility of lowering the age of criminal responsibility to 14. From age 12 to 15 children are kept in juvenile correction centers.
Russia 16 by default, 14 years specifically for crimes as listed in Section 20 of the Criminal code, like murder, rape, robbery, extortion, kidnapping, motor vehicle theft, terror attack, stealing restricted substances like explosives or narcotics, aggravated anti-social behaviour, vandalism, false report of a terror attack.
South Africa The Child Justice Act 75 of 2008 came into effect 1 April 2010. There is a rebuttable presumption that a child between the ages of 10 and 14 lacks criminal capacity.
United States url= http://www.national.org.nz/Article.aspx?ArticleID=3882 |title= Saving a generation of young people |first=Don |last=Brash |authorlink= Don Brash |publisher= New Zealand National Party |date = 21 March 2005 |accessdate= 31 October 2012}}</ref>; however, only 15 states have set minimum ages, which range from 6 to 12 years. States without statutory minimum ages rely on common law, which means that 7 is the minimum age in most states; for federal crimes the age has been set at 11.
Vietnam Age 14 - under 16 only for very serious criminal

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