Key legal question
Whether bank 'administration fees' for securities holdings are deductible portfolio-management costs under Art. 32(1) DBG.
Extracted holding
Only expenses directly serving the earning of income count as deductible third-party management costs; the disputed administration fees were in substance investment-advice or asset-allocation costs and thus non-deductible.
Extracted reasoning
Pure custody/depot fees and related incidental expenses are deductible. But fees for a comprehensive asset-management mandate, where the bank independently manages the portfolio according to the chosen strategy, are essentially advisory and acquisition/disposal-related costs. Such expenses fall under non-deductible living or investment-improvement costs.