Questione giuridica chiave
How should a retroactive disability pension payment be converted into taxable annual income under Art. 37 DBG?
Decisione estratta
The lump-sum back payment had to be divided by 76 months and then multiplied by 12; the payment date within 2002 was irrelevant.
Motivazione estratta
Art. 37 DBG applies to retroactive payments as well as future commuted periodic benefits. For payments covering a fixed number of months, the annualized amount must be derived schematically from the total sum and the covered period.