Kernrechtsfrage
Whether the vested benefits capital payment was subject to Swiss withholding tax rather than ordinary taxation in Solothurn.
Extrahierter Entscheid
The payment was taxable at source because, at the time it became due and was paid, the taxpayer no longer had a Swiss residence; the source taxation conditions were met.
Extrahierte Begründung
Under StHG and DBG, capital benefits from occupational pension plans paid to recipients abroad are subject to withholding tax. The decisive moment was the due date of the vested benefits payment, when the taxpayer had already deregistered and left Switzerland; ordinary taxation in Solothurn was therefore not required.