Questão jurídica principal
Whether the security order under Art. 169 DBG was justified by a risk to collection of the tax debt.
Decisão extraída
Yes. The objective circumstances, especially systematic concealment of assets and easily transferable cash holdings, made collection appear endangered.
Fundamentação extraída
Art. 169 DBG does not require a specific harmful act; a prima facie objective risk is enough. Hidden cash in several hundred thousand francs, assets held in easily realizable form, and links to the home country supported the risk.