The Constitutional Court has come to the conclusion that fines imposed on an organization for committing a tax offense are not subject to recovery from controlling persons by way of bringing them to subsidiary liability.

Ekaterina Kopylova, Tax Compliance tax consultant, commented on the legal position and rationale expressed in Resolution No. 50-P of 30.10.2023 in an article published in the EZh-Jurist newspaper.

The full text can be found at the link.