Kernrechtsfrage
Whether the creation of the foreign partnership on 7 November 1997 required an interim assessment due to a change in earning capacity.
Extrahierter Entscheid
No. The new activity did not amount to a fundamental change in the taxpayer's professional situation, and the existing salaried work continued essentially unchanged.
Extrahierte Begründung
Interim assessment under Art. 45 lit. b DBG requires a durable and substantial change in earning bases; a mere additional or competing activity is insufficient, especially where the prior employment remains essentially unchanged.