Key legal question
Whether association A qualifies for tax exemption as a charitable organization under Art. 56 lit. g DBG and § 90 Abs. 1 lit. i StG.
Extracted holding
Yes. A is a legal person pursuing exclusively public-benefit purposes, with irrevocably dedicated assets and actual implementation of its statutory purpose.
Extracted reasoning
The association promotes art and provides low-cost housing and practice space to needy artists and art students, without pursuing its own economic interests. The funds are tied to the statutory purpose, the purpose is actually implemented, and the open beneficiary circle and low rents show altruistic, non-profit activity.