Questione giuridica chiave
Whether the German BfA annuity is taxable in Switzerland as an ordinary social security pension or only partially as a life annuity
Decisione estratta
The annuity is a social security pension under Art. 22(1) LIFD and is taxable in full; the reduced 40% taxation for life annuities does not apply.
Motivazione estratta
The BfA pension is analogous to an AVS/AI-type social insurance benefit from a public foreign institution. Because the taxpayer could deduct at least part of the contributions and the entitlement did not represent a privately financed life annuity, Art. 22(3) LIFD is inapplicable.