Record fine from the TCC: how an ordinary man ended up with a quarter of a million debt
24 April 15:48
Recently, the President signed a law on a 50% discount for voluntary payment of fines from the Transfer Pricing Commission. That is, if the first fine is UAH 17,000, it is possible to pay only UAH 8,500.
Since the beginning of 2025, about 4,700 new enforcement proceedings have been opened in Ukraine every month due to non-payment of fines from the TCC. In total, there are 17,007 cases against 15,772 people, of which only 16% (2,779 cases) have been closed, according to Opendatabot.
During the three years of war, almost 29,000 debts for violating the rules of military registration have accumulated, and the accounts of about 26,000 citizens have been blocked. At the same time, almost 52% of the debts for the past year remained unpaid. There are also “record holders” in terms of non-payment of fines from the TCC – seven administrative protocols were drawn up against an Odesa resident. And he is not the only one. A resident of Kyiv region received a record fine from the TCC – UAH 224,000. Komersant found out what to do in this case.
A quarter of a million for an administrative violation is a record for Ukraine
According to lawyer Roman Simutin, a client contacted him and said that he had already accumulated UAH 224,000 in administrative protocols from the TCC, and when they started to investigate, it turned out that the person liable for military service had been issued 4 protocols for UAH 25,500 at the end of November 2024. That is, the initial amount of UAH 102,000 doubled over time, and a 10% enforcement fee was added – UAH 20,400.
We have the following selection of administrative decisions under Article 210-1 of the Code of Administrative Offenses – violation of the legislation on mobilization during a special period:
- refusal to undergo the preliminary medical examination;
- failure to provide a military registration document at the request of a representative of the CMC;
- failure to register for military service upon reaching the age of 27;
- failure to update military registration data.
And people who are unaware of their rights and legislation, having received a pile of penalty notices, simply grab their heads and dutifully pay everything. But such demands are legal nonsense, the lawyer notes.
“The sanction of Article 210-1 of the Code of Administrative Offenses for violation of the legislation on mobilization during a special period provides for a fine ranging from UAH 17,000 to UAH 25,500. And only within these limits, there is no room for imagination – everything is clear. And Article 36 of the Code of Administrative Offenses states: “If a person has committed several administrative offenses, the cases of which are simultaneously considered by the same body (official), the penalty is imposed within the sanction established for the more serious offense among the committed ones.” But all four reports against the man were drawn up on the same day – November 25, 2024. Therefore, in accordance with the requirements of Article 36 of the Code of Administrative Offenses, the amount of the fine may not exceed the maximum determined by the sanction of Article 210-1 of the Code of Administrative Offenses, i.e. UAH 25,500. Period. There is no other interpretation,” emphasizes Roman Simutin.
Fines are illegal
If you do not appeal against such a “package” of fines from the TCC, you will definitely be forced to pay all these unreasonably accrued amounts. And if you miss the deadline for appealing – that is, if you find out about the fine and do not file a lawsuit within ten days – the court will not renew the deadline, and you will have to pay everything that has been charged.
And this is despite the fact that such a fine is absolutely illegal. And it would be one thing if the TCC did not know about it. But they do know – and they still issue them, the lawyer notes and adds that he recently had a client who was issued a hefty fine of UAH 68,000 by the TCC. After non-payment and the opening of enforcement proceedings, it turned into UAH 136,000 of principal plus an enforcement fee.
“This fine can be successfully appealed, up to its complete cancellation. Because four penalties were imposed illegally, and the fines were issued without summoning the person liable for military service to consider the case of an administrative violation, which is a clear basis for canceling the decisions. That is why such fines are canceled in 99% of cases,” emphasizes Roman Simutin.
The lawyers insist that fines cannot be delayed. All these issues need to be resolved immediately. Moreover, even paying a fine does not guarantee that a person will be removed from the wanted list. On the contrary, as Roman Simutin clarifies, it is impossible to be removed from the wanted list even after paying the fine. And after agreeing and paying, the next step may be criminal liability under Article 337 of the Criminal Code of Ukraine.
“You can be removed from the wanted list only if the fine is canceled and the court decision is enforced. Failure to comply will result in a fine of UAH 120,000 for the head of the TCC. That is why the payment of UAH 8,500 by men liable for military service who are not entitled to a deferment may result in even bigger problems. Therefore, leaving the fines “in the air” and not appealing them – if you have not received a summons – is not an option,” the lawyer advises.
The lawyers strongly recommend not to bring the situation to administrative responsibility and to update your data in the TCC in time.
Author: Alla Dunina
