Question juridique clé
Whether the pension fund buy-in could be deducted as an extraordinary expense in the 1999/2000 tax period under § 263 StG/AG and Art. 69 StHG.
Solution extraite
No. The deduction was unavailable because the taxpayers were not still subject to unlimited tax liability in Aargau on 1 January 2001, as required by § 263(4) StG/AG; the cantonal rule properly implements Art. 69(4)(a) StHG.
Motifs extraits
The court held that Art. 69(4)(a) StHG is meant to prevent a loss of deduction only when caused by the system change, not when the loss results from a move out of the taxing canton. The taxpayers did not engage with this core reasoning.