Question juridique clé
Whether Art. 21 lit. e LCP can be applied before determining the inter-cantonal apportionment of debts under Art. 40 LCP.
Solution extraite
Art. 21 lit. e LCP applies only after identifying the deductible debts and, in inter-cantonal cases, after apportioning them under Art. 40 LCP.
Motifs extraits
The provision concerns income calculation but presupposes assets and debts relevant to wealth tax. One must first determine which debts are deductible; only then can the corresponding deductible interest be calculated. Where assets are located in several cantons, that debt allocation must be carried out under Art. 40 LCP before the limitation in Art. 21 lit. e LCP is applied.