Question juridique clé
Whether the same 5.5 million transfer was subject to unconstitutional intercantonal double taxation.
Solution extraite
Yes. Nidwalden unlawfully taxed a transfer that Ticino correctly treated as a legacy/inheritance item.
Motifs extraits
The transfer was economically a mortis causa acquisition, not a voluntary inter vivos gift; the contractual form did not change the underlying inheritance character. Ticino, as the place of the decedent's last residence, had the taxing right for the legacy.