Questão jurídica principal
Whether the CHF 120,000 pension buyback was deductible from source-taxable income.
Decisão extraída
No. The buyback had to be disregarded because it constituted tax evasion.
Fundamentação extraída
The buyback was made shortly before termination of employment and departure from Switzerland, while the taxpayer kept a practically unchanged retirement benefit. In that context the buyback was unusual and served mainly to obtain a notable tax saving rather than to build genuine occupational pension coverage.