Question juridique clé
Whether the Italian apartment and its rental value could be considered for Swiss income and wealth tax rates.
Solution extraite
Yes. Although the foreign immovable property itself was exempt from Swiss taxation, it had to be taken into account to determine the applicable progressive rate for Swiss-taxable income and wealth.
Motifs extraits
Under Swiss domestic law and the double-tax treaty with Italy, foreign items exempt from taxation still influence the rate. Progressive taxation and ability-to-pay require considering worldwide elements to avoid unjustified advantage.