Questão jurídica principal
Whether the claims for customs duties and import VAT were time-barred
Decisão extraída
No; the limitation period had not expired under the applicable transitional rules, and the later pendency of the liability proceedings suspended the running of time.
Fundamentação extraída
The relevant offenses dated from 1995-1997. Under Art. 12(4) VStrR in connection with Art. 11(2) and (3) VStrR, and applying the lex mitior analysis, the liability claims were still timely when the first-instance liability decisions were issued.