Facts
The Public Prosecutor's Office in Freiburg i.Br. is conducting an investigation against [A.] and [B.] on suspicion of tax evasion in favor of [C. GmbH] . The accused are alleged to have evaded corporate income tax and the solidarity surcharge amounting to at least 1'131'450.62 euros in the years 2000-2003 by transferring operating expenses based on forged contracts to inactive foreign companies (including the complainant [X.] Ltd.). The Public Prosecutor's Office in Freiburg requested legal assistance from Switzerland, in particular the release of documents relating to the account of [X.] Ltd. at Bank [G.] . The Swiss authorities complied with the request for legal assistance. [X.] Ltd. filed an administrative court appeal against this.Considerations
The Federal Court dismisses the appeal. It considers the requirements for legal assistance to be fulfilled, as the request for legal assistance indicates a suspicion of tax fraud under Swiss law. The accused are alleged to have acted fraudulently through the use of forged contracts and an incorrect balance sheet, thereby evading taxes to a significant extent. Such machinations are to be qualified as "manoeuvres frauduleuses" within the meaning of the…