Summary The subject of this thesis is the punishment of acts of preparation. The main question regards the interpretation of art. 46 of the Dutch penal code (Sr). This is a relatively new subject in Dutch criminal law. The comparative approach is chosen to develop more theory about this subject. This comparative study is meant to lead to new perception about the criminal preparation. The preparation of crimes is not described as an isolated subject. Every description of the preparation in the four different countries is preceded by a study of the main subjects of substantial criminal law; criminal liability, participation and attempt. Chapter 2 describes the current Dutch law on the subjects as listed above. A description is given of the development of the concepts of criminal liability and accomplishment. Both concepts were at first seen as mainly physical. Later on the doctrine has developed a more mental concept of criminal liability. It is not only the person who physically commits the crime who can be a perpetrator, but also the person who can be held responsible for that act. This development has also influenced the different forms of participation in crime. The interest of some of those forms of participation is diminished; on the other hand some forms of participation have been substantially expanded. The concept of attempt has also changed. Both in jurisprudence and in doctrine, one has been balancing between objective and subjective theories. At the beginning of the twentieth century, the balance seemed to shift in the objective direction. Later on, the subjective elements of the attempt have become more important. In the second chapter, the main questions according to the law of criminal preparation in art. 46 Sr have been established. Those are meant to be answered in the last chapter after the study of the three foreign law systems. The third chapter is the first of three comparative chapters and describes the German law on the subjects of criminal liability, participation, attempt and preparation. ...