Questão jurídica principal
Whether the recourant could invoke inter-cantonal anti-double-taxation rules to halve his Vaud taxable income and wealth in an international situation.
Decisão extraída
The inter-cantonal split rule does not apply in this international setting; the recourant remained fully taxable in Switzerland under the relevant domestic law.
Fundamentação extraída
The double tax treaty allocated taxing competence to Switzerland, but its negative effect could not create a domestic tax basis or determine the extent of Swiss cantonal taxation. The Vaud renvoi in Art. 6 al. 3 LI must be read in light of the federal rule structure and does not incorporate rules meaningful only between cantons.