Question juridique clé
Whether procedural costs from the objection proceedings could be imposed on the appellant under § 27a GGStG
Solution extraite
No. Because the statutory prerequisites under § 27a GGStG were not met, the costs from the objection proceedings could not be charged to the appellant.
Motifs extraits
Under § 27a GGStG, costs may be passed on only after an unsuccessful warning and a fine by the tax authority for failure to submit the self-assessment or required evidence. It is undisputed that the appellant failed to comply with his procedural duties, but he was neither warned nor fined. The required precondition was therefore missing.