Questão jurídica principal
Whether simultaneous taxation of the corporation in its seat canton and the shareholder in the canton of residence is unconstitutional double taxation.
Decisão extraída
No. The concurrent taxation of the company’s capital and the shareholder’s shares is not unconstitutional double taxation, even for a family corporation.
Fundamentação extraída
The Court reaffirmed its settled case law. A family corporation remains a separate legal entity, and the proposed distinction would be impossible to administer by workable legal or economic criteria.