Question juridique clé
Whether the tax security order of 7 July 2017 could serve as a definitive legal-opening title despite being challenged on appeal.
Solution extraite
Yes. A tax security order is immediately enforceable and has the same effect as an enforceable judgment in enforcement proceedings; the pending appeal did not suspend enforcement.
Motifs extraits
Under the applicable tax and debt-enforcement provisions, enforceability, not formal finality, is decisive for definitive legal opening. Since the order is immediately enforceable and the appeal has no suspensive effect, the creditor had a valid title.