Kernrechtsfrage
Whether the salary of a sole shareholder-manager may be taxed under the simplified procedure for small wages (VAV).
Extrahierter Entscheid
No. The simplified procedure was not available for the appellant's own manager salary; it was intended primarily for third-party employees and not for employer and employee in one person.
Extrahierte Begründung
Although the formal conditions of the statute were met, applying the VAV to the appellant would defeat its purpose of combating undeclared work by third parties. The arrangement was considered a misuse of the scheme and a tax avoidance structure.