Questão jurídica principal
Whether the taxpayer established a new tax domicile in Thailand for tax period 2011
Decisão extraída
No. He failed to prove that the center of his life interests shifted to Thailand; his Swiss tax domicile in M. continued in 2011.
Fundamentação extraída
Despite longer physical presence in Thailand, the court found the marital relationship, common living arrangements, and stronger social ties remained centered in Switzerland. Formal indicators such as deregistration, foreign permit, or passport entries were not decisive.