Subject of Dispute: Challenging a Tax Notice-Decision on Penalty Accrual for Violation of Currency Legislation in Foreign Economic Activity.
Key Arguments of the Court:
The Supreme Court deviated from previous legal positions and established that penalties for violation of currency legislation during quarantine do not fall under the preferential provisions of the Tax Code. The Court pointed out that provisions on suspension of terms do not apply to currency transactions, and previous court decisions were erroneous.
Court Decision: The Supreme Court revoked the decisions of previous instances and referred the case for a new review to the appellate administrative court for a comprehensive and thorough investigation of the circumstances.