Question juridique clé
Whether the 20-year period for deferred wealth tax under Art. 308a LT / Art. 14(2) StHG starts with the first preferential taxation period or with the change of use/alienation.
Solution extraite
The period is counted backward from the change of use or alienation, i.e. the last 20 years before the taxable event.
Motifs extraits
Although the cantonal wording could suggest an initial-period approach, the federal harmonization rule and its purpose require reference to the period immediately preceding the event triggering supplementary taxation.