Art. 191 Tax Law (TL)

1 If the taxpayer does not have a domicile in Switzerland or if the tax claim appears to be at risk, the Tax Service may require security at any time, even before the tax amount is determined by a final and binding decision.

2 The request for security specifies the amount to be secured; it is immediately enforceable. In the enforcement procedure, it has the same effect as an enforceable judgment.

3 Security must be provided in cash, in secure and negotiable securities, or in the form of a guarantee from a bank or two solvent joint guarantors.

3a Article 136a applies to the representation of the taxpayer and the notification of the security request decision.

4 The decision to request security is subject to an administrative law appeal to the Administrative Court within 30 days following its notification; it is not subject to opposition.

5 The appeal does not suspend the execution of the request for security.

6 The attachment procedure according to the provisions of the federal law on debt enforcement and bankruptcy is reserved.

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