Questione giuridica chiave
Whether the seized electronic records had to be returned or fully placed on file for the tax investigation
Decisione estratta
The lower court’s blanket return of the CDs could not stand; the records had to be reconsidered with a presumption of disclosure for documents relevant to the investigation.
Motivazione estratta
The Federal Court held that the lower court relied on a superficial and purely quantitative assessment. Given the current state of the case, professional secrecy could no longer be invoked in the same broad manner, and potentially relevant documents could not be withheld merely because review would take time.