Key legal question
Whether Art. 17 LAMal allowed loss offsetting between social health insurance and supplementary insurance for tax purposes
Extracted holding
No. The tax exemption covers only the social-health-insurance sector; supplementary-insurance profits remain taxable and may only offset losses within that sector.
Extracted reasoning
The insurer must keep separate accounts and autonomous financing for the mandatory social insurance. Resources from the exempt sector may not be used to finance supplementary insurance, and vice versa.