Questione giuridica chiave
Whether the taxpayers were subject to unlimited tax liability in Zurich or Obwalden for 2006
Decisione estratta
Their personal and tax residence remained in Zurich; no effective transfer of the center of life to Obwalden was proven.
Motivazione estratta
For retired persons, the main tax domicile depends on the center of life shown by objective circumstances. The move to Obwalden was not sufficiently completed: the Zurich home was retained and apparently still used, the new residence was temporary, and the later return to Zurich supported continued ties there.