Question juridique clé
Whether negative compensatory interest under cantonal tax law could be charged on the unpaid balance of 2008 cantonal taxes from 31 March 2009.
Solution extraite
Yes. The unpaid balance of the direct cantonal tax remained outstanding at general maturity, so compensatory negative interest was due until extinction of the debt.
Motifs extraits
Art. 164a para. 5 LF applies to amounts still due at the general due date. Withholding tax does not retroactively extinguish the cantonal tax debt before it becomes payable; it is only credited later when due.