Art. 6 Direct Taxation Act (DTA), of March 21, 2000
Art. 6 Direct Taxation Act (DTA), of March 21, 2000
[6] 1 Natural persons who, under tax law, are neither domiciled nor staying in Switzerland are subject to tax due to their economic ties when
a) they engage in gainful activity in the canton;
b) in their capacity as members of the administration or management of a legal entity that has its seat or a permanent establishment in the canton, they receive bonuses, attendance fees, fixed compensation, employee participation, or other remunerations;
c) they hold or benefit from claims secured by a mortgage or pledge on real estate located in the canton;
d) as a result of activities on behalf of others governed by public law, they receive pensions, retirements, or other benefits from an employer or a pension fund that has its seat in the canton;
e) they receive income from occupational pension plans or from other recognized forms of tied individual pension plans from private law institutions with their seat or permanent establishment in the canton;
f) due to their activity in international transport aboard a ship, aircraft, or road vehicle, they receive a salary or other remuneration from an employer with its seat or permanent establishment in the canton;
g) they act as intermediaries in commercial transactions involving real estate located in the canton.
2. When, in place of one of the aforementioned persons, the payment is made to a third party, it is the latter who is subject to tax.