Key legal question
Whether the taxpayers were entitled to an interim assessment under § 78 lit. a StG due to a job change and income reduction.
Extracted holding
No. Although the income change exceeded the statutory threshold, the husband remained in his trained commercial profession and did not undergo a deep structural change in his occupational situation.
Extracted reasoning
Interim assessment grounds are exceptional and must be construed narrowly. A professional change requires a fundamental structural shift, such as moving to a different field where prior skills can no longer be used. Here, the taxpayer stayed employed as a commercial employee and later as managing director; the change concerned duties, not profession.