Kernrechtsfrage
Whether the request disclosed sufficient indications of punishable tax fraud rather than mere tax evasion.
Extrahierter Entscheid
The request contained concrete allegations of a complex deceptive scheme amounting to tax fraud under Swiss standards, with sufficient suspicion of arglist.
Extrahierte Begründung
The court held that hidden control of the Swiss company, unusual rebates, waiver of advances, loan arrangements, and underpriced share transfers together formed a deceptive structure difficult for tax authorities to detect.