Questão jurídica principal
Whether cantonal payments for operating the Gassenzimmer and outreach drug work were subsidies or taxable consideration.
Decisão extraída
The payments were consideration for services, not subsidies, because there was a contractual exchange and economic linkage between the canton and the company.
Fundamentação extraída
The company was contractually bound to provide defined services; the canton sought to procure performance of its public and contractual obligations, not merely support a chosen activity. Therefore the payments had the character of taxable remuneration.