Kernrechtsfrage
Whether the full retroactive disability pension amount, including amounts transferred directly to the social welfare authority, is taxable income for 2006.
Extrahierter Entscheid
Yes. The pension entitlements were taxable when acquired, and the direct transfer to reimburse social assistance did not change taxability.
Extrahierte Begründung
Under harmonized tax law, disability pensions from first and second pillar schemes are generally fully taxable. The set-off against social assistance debts is a non-deductible debt repayment expense, not a deductible earning expense or authorized social deduction.