Questão jurídica principal
Whether the underpriced sale of Y. AG shares constituted a hidden profit distribution taxable as income.
Decisão extraída
Yes, the price was below market value; the difference of CHF 138,417 was a hidden profit distribution to A.S.
Fundamentação extraída
For pure asset-management companies, market value is determined by net asset value; the tax authority properly considered reserves and latent taxes, and a third-party comparison showed underpricing.