Exclusion of private contractual settlement payments from § 3 No. 3 EStG tax exemption

The Federal Constitutional Court dismissed the constitutional complaint without a substantive reasoning, meaning the lower court's refusal to apply the tax exemption to the taxpayer's private settlement payments remains in force, and the taxpayer did not prevail. The dispute concerned a taxpayer who challenged the Bundesfinanzhof's denial of the exemption for certain benefits under § 3 No. 3 EStG, arguing that payments made pursuant to a private settlement agreement regarding the termination of an employment relationship should be treated as equivalent to statutory severance pay and thus be tax-free. The decisive legal basis was the interpretation of § 3 No. 3 EStG, which the federal tax courts held did not cover payments derived from private contractual agreements (Vertragliche Abfindungen) as they lacked the specific statutory character required for the exemption, thereby upholding the original tax assessment.