Key legal question
Whether the sealed tax-investigation documents had to be produced in full and unredacted despite claimed professional secrecy and workload concerns.
Extracted holding
The documents had to be filed, as a rule in full and unredacted, because the public interest in investigating serious suspected tax offences prevailed and the asserted attorney-client privilege was largely not protectable on the facts.
Extracted reasoning
The court reiterated that a merely quantitative argument about the effort of sorting and anonymising is insufficient. Where business and legal functions are intertwined and the privilege is invoked only generically, the reviewing court may require filing; only some documents may exceptionally be anonymized. The lower court's proportionality reasoning was inconsistent with prior Federal Tribunal rulings.