Key legal question
Whether the Brugg taxation created impermissible international double taxation
Extracted holding
The complaint failed because the appellant did not show that the Brugg assets were also subject to another tax sovereignty, and the Court would not extend its double-taxation case law beyond its existing limits.
Extracted reasoning
The Court reaffirmed its prior practice: protection against international tax conflicts existed only for foreign immovable property already taxed abroad and taxed again in Switzerland. That situation was not present here, and no compelling federal-law reasons justified expanding the doctrine.