Questione giuridica chiave
Whether the proportional stamp duty may be levied by a canton other than the one where the written deed was completed.
Decisione estratta
A proportional stamp duty based on the value stated in a written deed is a tax subject to Art. 46(2) Cst.; it may be levied only by the canton where the deed was created, meaning where it was drafted and signed.
Motivazione estratta
Fiscal sovereignty belongs to the canton where the instrument became complete. If several persons must sign, the deed becomes complete only upon the last signature. If signatures are affixed in different cantons, taxing power belongs to the canton where the last signature was given.