Questione giuridica chiave
Which canton may tax the pension capital payment after the taxpayers changed residence during the tax period?
Decisione estratta
The decisive time is the maturity of the vested-benefits payment; because the entitlement matured while the taxpayers still lived in Schwyz, the payment is taxable in Schwyz, not Zurich.
Motivazione estratta
For cash-outs under Art. 5(1)(b) FZG, once the withdrawal conditions are met and the claim becomes due, the income is realized for tax purposes even if payment occurs later. Practicality and tax planning concerns do not justify using the actual payment date.