Questione giuridica chiave
Whether pension buy-ins made shortly before capital withdrawals are deductible from taxable income under the three-year lock-up rule.
Decisione estratta
No deduction is allowed because Art. 79b(3) BVG bars capital withdrawals within three years of the buy-ins.
Motivazione estratta
The court reaffirmed its case law that the provision prevents deduction of any contribution made during the lock-up period, even if the pension model separates later contributions from later benefits.