Questione giuridica chiave
Whether the sealed documents from the law office had to be placed in the file despite claimed attorney-client privilege and workload concerns.
Decisione estratta
The documents had to be filed, generally in non-anonymized form, because the public interest in investigating serious tax offenses prevailed and the privilege could no longer be broadly invoked.
Motivazione estratta
The lower court relied on a sweeping proportionality argument and on a generalized privilege claim. The Federal Tribunal held this approach incompatible with its prior rulings: the distinction between protected and unprotected material was not sufficiently clear, many documents related to non-typical legal work, and a concrete examination of privilege was required only for limited documents.