Facts

The appellants [A.] , [B.] and [C.] were convicted by the High Court of the Canton of Zurich for multiple evasion of value added tax within the meaning of Art. 96 para. 4 lit. a VATA. The proceedings concerned the allegation that the appellants had imported artworks tax-free into Switzerland through the gallery [H.] under the deferment procedure, although the beneficial owners of the artworks were [C.] and offshore companies controlled by him. As a result, the import tax actually owed was not paid. The High Court found that the gallery [H.] had only been used as a front as a commission agent and importer of the artworks. [C.] had remained entitled to dispose of the artworks imported under the deferment procedure at all times. The importation of the artworks was attributable to him. Had he declared himself as the principal of the imports and thus as the customs debtor, he would have had to pay the import tax without being able to subsequently claim input tax deduction. He had not complied with these customs obligations, which had led to a loss of import tax revenue for the state. [A.] acted as a lawyer for [C.] and founded the offshore companies that appeared as principals in the commission contracts. He signed the commission contracts or had them signed by employees of his law firm. [B.] made the gallery [H.] available as the holder of a permit for the deferment procedure and ordered the drafting of commission contracts. The gallery [H.] was primarily involved in the sending and receiving of the commission contracts, but had no power of disposal over the paintings, which were instead determined by [C.] or his administrative…