Questione giuridica chiave
Whether taxing the replacement reserve in wealth tax was arbitrary under Art. 9 BV.
Decisione estratta
No. The reserve was treated as an asset, and § 24bis aStG/AG concerned only income-tax treatment of reinvested hidden reserves, not wealth tax.
Motivazione estratta
The provision lies in the income-tax section and regulates only the exclusion of realized hidden reserves from income when earmarked for replacement; the wealth-tax section taxes total wealth without a corresponding exemption.