Kernrechtsfrage
Whether the BVG capital payment had to be taxed in 2003 or 2004.
Extrahierter Entscheid
The payment was taxable in 2004 because the decisive moment is the maturity of the pension claim, which arose only after the employment relationship ended on 31 December 2003, i.e. on 1 January 2004.
Extrahierte Begründung
Pension benefits are taxable only when due. Under the applicable rules and Art. 84 BVG, taxation before maturity is prohibited. Early transfer by the pension fund does not change the tax point; if the fund performs early, the obligation is extinguished, but maturity remains the decisive criterion.