The Supreme Court Regulation No. 3 (Perma 3/2025), which came into force on December 23, 2025, fundamentally changes the approach to criminal tax cases, focusing on state loss recovery and personal liability.
Key Changes
Expanded Scope of Liable Parties
– Criminal liability now clearly extends to legal entities (corporations).
– Not only formal executives but also actual beneficiaries and controllers can be held accountable, even if they are not part of the company’s official structure.
– Bankruptcy or liquidation of a company does not absolve its controllers from liability for past violations.
Separation of Administrative and Criminal Processes
Perma 3/2025 clearly distinguishes two paths:
– Administrative fines (tax office).
– Criminal prosecution (court).
These processes can now proceed in parallel and independently of each other.
Asset Seizure Made Easier
Investigators have received powerful tools to protect the state budget:
– Blocking of accounts and property upon request.
– Seizure of evidence (documents, records) — for conducting a criminal case, and seizure of assets (accounts, property) — to guarantee state loss recovery even before a verdict is issued.
– Emergency seizure of movable property in exceptional cases — even without prior court approval.
Consequences of Debt Repayment Depend on Timing
The timing of debt repayment critically influences the outcome of the case:
When is the debt repaid? | Criminal Consequences
During the investigation stage | Complete termination of the case is possible.
After the case is transferred to court | Mitigation of the sentence. For individuals — potential avoidance of imprisonment.
After the verdict is issued | Non-payment of the fine leads to seizure and sale of assets, and subsequently — to imprisonment.
Procedural Innovations
– Trials in absentia: The court can issue a verdict in the absence of a defendant who was properly notified but failed to appear.
– Death of the accused does not stop the state’s recovery of losses: it is possible to file a claim against heirs or confiscate already seized property.
Conclusions for Business from Yard Finance
Perma 3/2025 signals the dawn of a new era of stringent tax control. Risks are higher, and consequences are more serious.
What companies should do:
– Strengthen internal tax control.
– Prepare a complete and transparent package of financial documents.
– Assess tax risks for past periods.
– Inform executives and beneficiaries about personal risks.
Timely compliance with tax legislation is now a key strategy for protecting the business and its owners.
