Kernrechtsfrage
When is a pension fund backpayment triggered by a salary increase deductible for tax purposes?
Extrahierter Entscheid
The deduction is allowed in the tax period in which the salary increase takes effect, because the pension fund statutes make the backpayment due at that moment; the invoice date is irrelevant.
Extrahierte Begründung
The tax law contains no special rule for such backpayments. By analogy to the pension fund statutes, due date follows the increase in insured salary, not the later invoicing. The statutory rule ensures legal certainty and avoids arbitrary results depending on administrative processing time.