Question juridique clé
Whether the association qualifies for tax exemption as a charitable legal person under cantonal and federal tax law.
Solution extraite
No. The association did not show that its assets and profits were irrevocably dedicated to charitable purposes, and its statutes left the beneficiary circle and use of the lodge too open to member control.
Motifs extraits
Charitable purpose requires both general interest and selflessness. The statutes allowed the lodge primarily for the scout movement and other users only at the board's discretion, with no binding duty to charge cost-covering or concessional fees or to serve an open circle. The required irrevocable dedication was therefore missing.