Question juridique clé
Whether the payments from the Zurich Vie contract were taxable as capital redemption installments or as life annuities
Solution extraite
The contract was a temporary life annuity, not a capital insurance policy; the payments were therefore taxable under the annuity rule.
Motifs extraits
The insurance still contained a life-risk element, the periodic payments depended on the insured person's life, and the surrender/restitution clauses did not change the contract's annuity character.