Question juridique clé
Whether the association was entitled to tax exemption retroactively from its founding date.
Solution extraite
No. Tax exemption is granted only from the tax year in which the exemption application is filed.
Motifs extraits
The court upheld the cantonal practice previously confirmed in case law: the taxpayer chooses when to apply, and retroactive exemption would create revision issues. The association had never applied before 2015 and could not claim a de facto exemption.