Key legal question
Whether the monthly payments from P. Holding B.V. are taxable as annuity income at 40 percent or only as a time-rent with interest portion.
Extracted holding
The payments were genuine life annuity payments and were taxable at 40 percent under Art. 22(3) DBG.
Extracted reasoning
The contract remained life-contingent; the capital depletion clause did not turn it into a mere term annuity, because the debtor's obligation still ended on death and life expectancy remained decisive.