Questão jurídica principal
Whether Thai housing and office rent could be deducted as business expenses from the consulting fees subject to AHV contributions.
Decisão extraída
The claimed rent expenses were not proven as deductible expenses; the general rule excludes living costs, and the expatriate housing-cost exception did not apply because A. had already stayed in Thailand for more than one year.
Fundamentação extraída
The lower court's evidence assessment was not arbitrary. No proof showed regular rent payments from A.'s accounts, and the housing costs in question were living expenses. Rz. 3008 WML allows only limited expatriate housing-cost reimbursements for at most one year after relocation, which was exceeded here.