Question juridique clé
Whether the complaints could rely on the criminal indictment principle and hearing rights to challenge the tax-fine proceedings
Solution extraite
The indictment principle does not apply to tax-hinterziehung proceedings, and the right to be heard was not violated because X. had been informed of the alleged conduct and could comment on it.
Motifs extraits
Tax evasion proceedings are administrative in nature; the relevant conduct was always the same factual core, and procedural safeguards were respected.