Kernrechtsfrage
Whether cantonal payments for operating the Gassenzimmer and outreach drug work were subsidies or taxable consideration.
Extrahierter Entscheid
The payments were consideration for services, not subsidies, because there was a contractual exchange and economic linkage between the canton and the company.
Extrahierte Begründung
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.