The Limits of Aiding and Abetting in Tax Evasion by an Organization

The article examines the limits of criminal liability for aiding and abetting tax evasion by an organization. The main attention is paid to situations where the actions of an accountant, a financial worker or another person outwardly coincide with his ordinary professional duties, but are in fact used in the commission of the crime provided for by Article 199 of the Criminal Code of the Russian Federation. Based on the provisions of criminal law and modern judicial practice, the distinction between co-perpetration and aiding and abetting is studied, as well as the content of the intent of a person facilitating a tax crime. The significance of the introduction of Article 173.3 of the Criminal Code of the Russian Federation for the criminal-law assessment of the actions of persons ensuring fictitious document flow is also touched upon.