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Case No. 520/2941/24 dated 27/02/2025

Here is the translation:

1. Subject of Dispute: Challenging a tax notification-decision on accrual of penalties for violation of settlement terms in foreign economic activity.

2. Key Court Arguments:

: The Supreme Court deviated from previous practice and changed the approach to understanding force majeure circumstances.

– Chamber of Commerce and Industry certificate on force majeure is not an indisputable proof of impossibility of fulfilling obligations
– It is necessary to prove a causal relationship between force majeure circumstances and the impossibility of performing a specific obligation
– War itself does not automatically exempt from fulfilling obligations
– Penalties for currency transactions are accrued on general grounds, despite quarantine

3. Court Decision: Reject the claim and leave the tax notification-decision unchanged.

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