Questione giuridica chiave
Whether the July 7, 2017 tax security order was a valid title for definitive debt enforcement despite the pending appeal.
Decisione estratta
Yes. A tax security order is immediately enforceable and has the same effect in enforcement proceedings as a final judgment; the pending appeal did not stay enforcement.
Motivazione estratta
Art. 169 DBG and § 194 StG provide immediate enforceability; under Art. 169(4) DBG and § 184(2) StG, the appeal has no suspensive effect. Formal finality of the underlying tax decision is therefore unnecessary for legal opening.