Kernrechtsfrage
Whether the coin-collection partnership with Swiss created a taxable exchange of services or a non-taxable donation.
Extrahierter Entscheid
The arrangement was a taxable sponsorship exchange: the foundation provided advertising and promotional benefits, and Swiss paid with the collected funds.
Extrahierte Begründung
The contracts granted Swiss exclusive use of the foundation's name and image materials and marketing rights, showing a causal economic link between promotional services and payment; the passengers' donations did not alter that bilateral exchange.