Kernrechtsfrage
Whether the 2007 branch profit of CHF 319,423 was a taxable dividend/hidden distribution to the shareholders.
Extrahierter Entscheid
The profit was taxable as income at the shareholders' level; the offshore structure and undocumented loans did not disprove the transfer of value to them.
Extrahierte Begründung
The court found the structure opaque: the Swiss branch profits were booked in the foreign head office, while corresponding shareholder loans were not properly declared. In this international/offshore setting, strict proof of foreign payments and their recipients was required, and the taxpayers failed to show that the funds flowed to the head office rather than to them.