Kernrechtsfrage
Whether the 2004 pension paid by the German DRV must be fully taxed in Switzerland
Extrahierter Entscheid
Yes. The DRV pension is taxable in Switzerland at 100% as comparable to an AHV pension.
Extrahierte Begründung
Under the Switzerland-Germany tax treaty, social security pensions are taxable only in the state of residence. Under cantonal and harmonized law, AHV-type benefits are fully taxable; the DRV pension is structurally comparable to an AHV pension, not a life annuity.