CONCURRING OPINION OF JUDGE THOMASSEN

I agree with the majority of my colleagues as regards the outcome of this case.

Nevertheless, I have some reservations with regard to the more general reasoning of the majority of the Court concerning the relation between the presumptio innocentiae and the early enforcement of tax penalties in general.

My reservations are – mutatis mutandis – set out in my concurring opinion in the case of Janosevic v. Sweden (no. 34619/97), delivered on the same day as the present judgment.

PARTLY DISSENTING OPINION OF JUDGE CASADEVALL

( Translation )

I do not share the majority's view on the last of the applicants' complaints. For the same reasons and applying the same principles as set out in my partly dissenting opinion in the case of Janosevic v. Sweden (no. 34619/97, delivered on the same day), I consider that the execution of the tax surcharges imposed by the Tax Authority before the courts were able to determine whether the applicants had any criminal liability also infringed Article 6 § 2 of the Convention.