Questione giuridica chiave
Whether the CHF 150,000 pension fund buy-in in 2000 was deductible despite earlier WEF withdrawals.
Decisione estratta
No. The buy-in was an unusual arrangement amounting to tax avoidance, so the deduction had to be denied.
Motivazione estratta
The taxpayers had made large WEF withdrawals shortly before or alongside renewed buy-ins, without showing non-tax motives. The sequence merely shifted assets temporarily into tied pension assets and back to freely available capital, contrary to the pension purpose, and generated a substantial tax saving.