Kernrechtsfrage
Whether the right to assess supplemental taxes for the 1999 and 2000 tax periods was time-barred.
Extrahierter Entscheid
Yes. The absolute limitation period expired 15 years after the end of each tax period, so the right to assess supplemental taxes had lapsed.
Extrahierte Begründung
Art. 152(3) DBG and § 171(3) StG establish an absolute forfeiture period, which is considered ex officio in public law and does not pause during proceedings. For 1999 it expired by 2014, and for 2000 no later than 2015.