Tax allocation outside the canton requires genuine operational presence
In decision 9C_349/2025, the Federal Supreme Court rejected the separation of self-employed income into another canton. The business office center used did not constitute a permanent business facility.
The decisive factor was that preparation, administration, and organization were predominantly carried out at the place of residence, where there was also a recognized study. Digital mail forwarding and occasional use do not replace operational substance.
The practice is clear: anyone who wants to pay tax on income outside their canton must actually work there – not just be present.
#Tax domicile #Sole proprietorship #Federal Supreme Court #Intercantonal #Business center #Tax allocation
https://x.com/zugtrust/status/2018714842148794710
(c) Ludwig Limbeck AG, 2026, Autor: Rolf Limbeck