Campos Sánchez-Bordona proposes that the Court reply as follows to the questions referred for a preliminary ruling: Article 50 of the Charter of Fundamental Rights of the European Union, is not applicable where there are two sets of proceedings and both administrative and criminal penalties in respect of the same offence and the tax penalties are imposed on a legal person, such as a company, while the criminal proceedings are brought against a natural person, even if that person is the legal representative of the company.