Question juridique clé
Whether the taxpayer was entitled to intermediate taxation under cantonal and harmonized tax law after reducing his work rate by 20%
Solution extraite
No. A 20% reduction in activity, without a change of profession or cessation of gainful activity, does not meet the objective conditions for intermediate taxation.
Motifs extraits
Intermediate taxation under Art. 17 LHID and Art. 80 LI requires a durable and essential change in the bases of gainful activity. The court applied the restrictive case law and found that the taxpayer merely reduced his employment rate, causing no qualifying structural change.