Questione giuridica chiave
When did the pension capital from occupational pension provision accrue for tax purposes: in 2003 or 2004?
Decisione estratta
The taxable accrual date was 2004, at the original maturity date on 2004-01-01, not the early transfer date of 2003-12-31.
Motivazione estratta
A pension claim is taxed when it becomes due and available. Under BVG, the early payment could not shift the tax period; the decisive date is the original maturity date, even if payment occurred one day earlier.