Kernrechtsfrage
Whether the capital payment from the foundation qualifies for privileged taxation as a pension-related benefit.
Extrahierter Entscheid
Yes. The decisive factor is the purpose of the payment; here the capital payment had pension character and was made by a retirement-related provision entity.
Extrahierte Begründung
The foundation served to supplement occupational pension benefits, was bound to a defined group of employees, and paid the capital amount upon retirement/termination. Privileged taxation depends on the benefit’s purpose, not on how it was financed or structured.