Question juridique clé
Whether income from the taxpayer's private medical practice counts as self-employment taxable at the business location in Bern
Solution extraite
No. The activity was overall dependent employment; the private practice income remained taxable at the main tax domicile in Solothurn.
Motifs extraits
The taxpayer worked within the clinic organization, used its infrastructure and staff, had no own capital or independent organization, bore only part of the collection risk, and had no significant fixed costs beyond insurance. The clinic mainly bore the financial risk.