Question juridique clé
Whether the 1998 training costs had to be deductible in Thurgau despite the move and the simultaneous system change.
Solution extraite
No. Under the double-taxation rules, Thurgau was not required to allow deductions for expenses incurred before the move, and Art. 69 StHG did not create a continuing deduction claim across a canton change.
Motifs extraits
Art. 69 StHG only protects extraordinary expenses if tax liability continues in the same canton after the system switch. Art. 78b StHG was not yet applicable and could not be applied analogically retroactively to 1998/1999.