Questão jurídica principal
Whether a home office in P. constituted a secondary establishment of the Zurich medical practice for intercantonal tax purposes
Decisão extraída
No. The activities at the home office were not qualitatively and quantitatively essential, so no secondary establishment existed in Aargau.
Fundamentação extraída
The home activities were limited to evening/weekend study and bookkeeping, had no patient contact and no external business presence, and were of merely subsidiary importance; the booked rent did not prove a materially relevant business contribution.