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Closing criminal proceedings for tax evasion: How can individuals who suffer from procedural pressure and, in fact, the existence of such proceedings fight for this?

authors: Alexander Minin, Oksana Hanushchak

10 April, 2026 Exclusive

Criminal proceedings for tax evasion are initiated relatively easily and pose significant risks to businesses, particularly affecting their reputation and commercial activities. Even in the absence of a formal notice of suspicion of committing a criminal offense under Article 212 of the Criminal Code of Ukraine, the conduct of procedural actions (such as interrogations and temporary access to items and documents) effectively confers on a person the status of a participant in the proceedings, along with the corresponding rights of defense.

Such cases are typically “personalized” in nature and, from the outset, are directed at specific officials (for example, a director or an accountant). The application of measures to secure the proceedings indicates reasonable suspicion, which may imply the emergence of a de facto status of suspect even without the formal service of a notice of suspicion. ...

 

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