Questione giuridica chiave
Whether a severance payment on termination of employment must be taxed separately for rate determination even if it is less than an annual salary.
Decisione estratta
No. Section 46 StG does not require the severance payment to reach at least one annual salary for annualization in the rate calculation.
Motivazione estratta
The statutory text contains no such restriction; the analogous federal rule also does not impose it. The lower court's additional condition lacked a legal basis and violated the legality principle, so the former practice had to be changed.