Question juridique clé
Whether the old Schwyz tax law allowed cantonal tax claims to escape limitation after timely initiation of assessment proceedings
Solution extraite
No. The court held that it is arbitrary to deny any limitation period for non-final tax claims once assessment proceedings have been timely initiated.
Motifs extraits
General administrative-law limitation principles apply even without an express rule. The cantonal law’s silence could not be treated as qualified silence excluding limitation, because comparable Swiss tax regimes and general limitation principles require a time limit for completion of assessment proceedings.