Questione giuridica chiave
For cantonal taxes, which canton may tax the one-time employment payments after the intra-Swiss move during the year?
Decisione estratta
The payments belong exclusively to Basel-Stadt; the cantonal judgment of Basel-Landschaft was unlawful on this point.
Motivazione estratta
For source-taxed persons subject to subsequent ordinary assessment after a cantonal move, Art. 38(4) StHG must be read as granting the canton of residence at the time of realization exclusive taxing power for the period in which the tax duty existed there. One-time items are therefore allocated to the realization canton, not prorated between cantons.