Question juridique clé
Whether the taxpayers were entitled to the maximum deduction for contributions to recognized pension forms.
Solution extraite
No. The maximum deduction requires active affiliation to a pension institution; a merely dormant, interest-bearing vested retirement balance is insufficient.
Motifs extraits
Art. 7(1)(a) BVV 3 presupposes active membership in occupational pension provision, meaning voluntary current contributions or comparable ongoing pension affiliation. A passive, frozen vested balance does not qualify and would create unequal treatment if treated the same as active coverage.