Question juridique clé
Whether the 2010 accruals for success fees and bonus were deductible business expenses.
Solution extraite
Yes. The payments were directly linked to the realized asset deal proceeds and had to be recognized in 2010.
Motifs extraits
The court held that the accruals were inseparably connected with the sale result. Applying the matching and realization principles, and respecting the massgeblichkeitsprinzip, the expenses were not aperiodic in a tax-detrimental sense.