Questione giuridica chiave
Whether, under Art. 22 DZV, the reduction of agricultural direct payments must be based on taxable income or on satzbestimmendes income when a backpaid IV pension is included in the tax assessment.
Decisione estratta
The relevant basis is taxable income under the direct federal tax rules, not satzbestimmendes income; the backpaid IV pension is taxable income and must be included.
Motivazione estratta
Art. 22 DZV expressly refers to taxable income. The tax law contains no rule requiring the amount to be adjusted because the pension was paid retroactively or relates economically to earlier years. The court held the regulation clear and not open to deviation.