Question juridique clé
Whether the sealed documents from the law office had to be produced in full or could be withheld/returned because anonymization would be disproportionate.
Solution extraite
The documents had to be produced, in principle in non-anonymized form, because the asserted professional secrecy no longer prevailed and the public interest in investigating serious tax offenses was stronger.
Motifs extraits
The lower court relied too mechanically on the number of third-party names and on supposed anonymization effort without actually examining the documents. The Federal Tribunal held that, given the case, the professional secrecy claim was largely excluded and the AFC needed access to the accounting records to verify completeness and correctness of declared income.