Kernrechtsfrage
Whether the VAT offences were time-barred at the time of the cantonal judgment
Extrahierter Entscheid
No. The ESTV inquiry letter of 28 August 2001 was an investigative act by a prosecuting authority directed against an adequately individualized suspect and interrupted limitation.
Extrahierte Begründung
The letter sought information to identify the person responsible for the defective VAT returns, was issued by an investigative officer under Art. 40 VStrR, and expressed the criminal claim against the responsible person. The suspect need not be named if sufficiently individualized.