Questione giuridica chiave
Whether BVG buy-ins are deductible under § 26 Abs. 1 StG even when made shortly before retirement and followed by a capital payout.
Decisione estratta
Such capital contributions are in principle fully deductible if they are provided for by the pension rules and are appropriate, even if made about one year before the statutory retirement age and the benefit is taken as capital.
Motivazione estratta
The deduction depends on the regulatory basis and the economic purpose of the buy-in, not on the short time remaining until retirement or the later form of benefit payment.