Questão jurídica principal
Whether the inter-cantonal pro rata allocation under Art. 38(4) StHG applied to income from employment, investment income, and wealth in later ordinary taxation.
Decisão extraída
The pro rata allocation applies only to employment income previously subject to withholding tax, not to investment income or wealth, which must be taxed ordinarily in the canton of residence at year-end.
Fundamentação extraída
Art. 38 StHG is systemically limited to withholding tax; the special pro rata rule is justified only for the withheld employment income and cannot be extended to assets or ordinary income components.