Kernrechtsfrage
Whether taxing the company's share capital at its seat while taxing the shareholder's shares at his domicile amounts to unconstitutional double taxation.
Extrahierter Entscheid
No. The simultaneous taxation of the shareholder's shares and the company's assets at its seat is not considered federally prohibited double taxation under settled case law.
Extrahierte Begründung
The Court relied on its consistent practice that an Aktiengesellschaft is a legal and economic organism independent from its shareholders, so both tax objects may coexist without violating federal law.