Kernrechtsfrage
Whether the EStV could order seizure/freezing of assets under Art. 46 VStrR during a special investigation for serious tax violations.
Extrahierter Entscheid
Yes. Art. 191 DBG expressly allows investigative measures under Arts. 19-50 VStrR, including preventive seizure under Art. 46(1)(b) VStrR, if forfeiture appears possible.
Extrahierte Begründung
The special investigation is a procedural tool of the tax administration. It is not displaced by the tax security regime under Art. 169 DBG. The court held that the lower court wrongly treated the future tax assessment as the exclusive route and ignored the independent procedural basis for seizure.