§ 6 Verordnung des Regierungsrates zum Bundesgesetz über die direkte Bundessteuer (DBG) - Notariat

VVGE.2011.13.Nr.44 · ow (Art. 3, 5 und 6 DBG)

Swiss Social Security Pensions Taxable in Italy, Not Switzerland

Cited as the basis for direct federal tax, relevant to the case.

VVGE.2011.13.Nr.44 · ow (Art. 6 Abs. 1 DBG)

Swiss Social Security Pensions Taxable in Italy, Not Switzerland

Cited to define unlimited tax liability based on personal affiliation.

VVGE.2011.13.Nr.44 · ow (Art. 6 Abs. 2 DBG)

Swiss Social Security Pensions Taxable in Italy, Not Switzerland

Cited to specify that tax liability is limited to income taxable in Switzerland.

VPB 1993-11-16 (Art. 6, 4e alinéa, LIFD)

Swiss Federal Ordinances and Regulations: Amendments, Taxation, Foreign Workers, and Sanctions

Cited as a basis for determining tax liability for individuals residing abroad and working for Swiss public entities.

A/4451/2022 · ge (art. 6 al. 2 LIFD)

Taxation of Cross-Border Employee Income Under Switzerland-France DTA

Cited as the basis for limited tax liability concerning the revenue from gainful employment.

B.2023.246.B.2023.2 · sg (Art. 6 Abs. 1 DBG)

Taxation of Income from Liechtenstein Partnership: No Foreign Permanent Establishment or Independent Services Exemption

Cited in the dispositive as the basis for denying the attribution of income to a foreign permanent establishment.

A/97/2024 · ge (art. 6 al. 3 3ème phr. LIFD)

Taxation of Relocated Individuals: Deduction of Prior Foreign Losses and Depreciation

The court addressed the request to consider past foreign losses for determining the tax rate in 2021, which is the core subject of the appeal's first point.

80.2023.141 · ti (art. 6'500.– per l’IFD)

Taxpayer v. Tax Authority: Dependent Deduction for Incapacitated Cohabiting Partner

The amount of the allowed deduction for the Federal Direct Tax (IFD) is stipulated in order 1 (§) as a consequence of admitting the appeal, corresponding to the maximum deduction under Art. 35 LIFD.

80.2022.259 · ti (Art. 6 capoverso 3 LIFD)

Swiss Tax Authority v. Foreign Entity (Loss Carry-Forward After Cross-Border Merger)

Cited as the method (objective method) that guarantees the necessary attribution of latent reserves to Switzerland for the maintenance of tax liability.

2020 · zh (Art. 6 Abs. 3 DBG)

Taxpayer Deduction of Foreign LLC Losses and Child Care Expenses

Mentioned in the reasoning section concerning the permanent rule for carry-forward/set-off of foreign business surpluses under federal law.

I.1.2021.26.und.27 · sg (Art. 6 Abs. 1 und 3 DBG)

Taxpayer's Permanent Establishment in Liechtenstein for 2019 Income Tax

Cited in the text preamble; their principles are applied analogously to justify the outcome for the direct federal tax.

I.1.2021.26.und.27 · sg (Art. 6 Abs. 1 und 3 DBG)

Swiss Resident v. Tax Authority (Liechtenstein Permanent Establishment)

These articles are cited as analogous to Art. 15 Abs. 1 StG concerning the restriction of tax liability due to a permanent establishment abroad, applied in the context of the federal direct tax.

FI.2021.0035 · vd (Art. 6 al. 2 LIFD)

Taxpayer v. Tax Authority Regarding Withholding Tax Reimbursement for Algerian Resident

This provision was cited in the reasoning regarding the scope of economic attachment but not explicitly in the dispositive (Orders I-III).

80.2020.217 · ti (art. 6 cpv. 1 e art. 7 LIFD)

Swiss Taxation of Liquidation Surplus Upon Company Transformation

Cited in the reasoning (Point 2.1) to establish the general principle of taxation, but not used in the final orders.

80.2020.217 · ti (art. 6 cpv. 3 LIFD)

Swiss Taxation of Liquidation Surplus Upon Company Transformation

Cited in the reasoning (Point 2.1) to establish jurisdiction rules, but not used in the final orders.