Question juridique clé
Whether A.A.'s Japanese teaching/research income could be taxed in Aargau under the Switzerland-Japan tax treaty.
Solution extraite
No. Article 15 DBA-JP allocates the income to Japan as the state of work performance, and Article 20 DBA-JP only grants an exemption in the state of activity; Switzerland may therefore tax it only for rate purposes.
Motifs extraits
The court held that Article 15 is the decisive allocation rule and that the professor clause is not an allocation norm but a pure exemption rule for the source/work state. The treaty does not leave Switzerland an additional taxing right.