Questione giuridica chiave
Whether income from real estate located in the United Kingdom was taxable in Switzerland for 1993/94
Decisione estratta
Income from foreign real estate was not subject to Swiss direct federal tax for that period and had to be excluded from the Swiss assessment.
Motivazione estratta
Under the applicable law, income from foreign immovable property was outside the tax base; the issue could also be raised on administrative judicial review as a matter to be considered ex officio.