Questione giuridica chiave
Whether the CHF 29,633 dismissal-related payment is exempt from income tax as a satisfaction payment under § 32 lit. g StG and Art. 24 lit. g DBG.
Decisione estratta
No. The taxpayer did not prove that the payment was a satisfaction payment for an abusive dismissal or another tax-exempt satisfaction claim.
Motivazione estratta
Although such payments may have a satisfaction function and can be agreed out of court, tax exemption requires proof of the underlying abusive dismissal or immaterial harm. The file did not establish an abusive dismissal; the parties' label was only an indication.