Kernrechtsfrage
Whether the customs authority's 1995 advice created protected reliance for Swiss domestic VAT on Kinder Surprise sales before 9 August 2000.
Extrahierter Entscheid
No protected reliance existed for domestic VAT because the customs authority was not competent to rule on inland VAT, and the request/answer concerned import VAT only.
Extrahierte Begründung
The court held that import VAT and domestic VAT are administered by different authorities. The customs advice clearly addressed only import taxation; the taxpayer could not reasonably assume it also bound the tax administration for inland VAT.