Art. 71 Legge tributaria (StG) - Appartenenza Fiscale a) Appartenenza Personale

B.2023.159 · sg (Art. 71 StG)

Principal Tax Domicile Versus Statutory Seat

Cited as part of the legal basis for determining tax liability based on personal affiliation (in conjunction with Art. 20 Abs. 1 StHG).

B.2023.160 · sg (Art. 71 StG)

Actual Management Determines Tax Domicile Over Statutory Seat

Cited in the reasoning to establish the basis for tax liability due to personal affiliation, which underpins the finding on the actual place of administration.

B.2023.159 · sg (Art. 71 StG)

Tax Domicile Determination: Actual Management Versus Statutory Seat

This article was used, alongside Art. 20 Abs. 1 StHG, to establish the basis for tax liability due to personal affiliation, central to determining the main tax domicile.

B.2023.160 · sg (Art. 71 StG)

Tax Domicile Determined by Actual Management Over Statutory Seat

This provision establishes the basis for tax liability due to personal affiliation under cantonal law, which was the central legal question addressed by the court's final order to dismiss the appeal.

B.2023.39 · sg (Art. 71 StG)

Place of Actual Management vs. Statutory Seat for Tax Domicile

This provision establishes the basis for the tax liability of legal entities in the canton (location of seat or actual administration), which is the core issue decided upon.

B.2023.39 · sg (Art. 71 StG)

Tax Domicile Dispute: Actual Place of Management vs. Statutory Seat

This article establishes tax liability based on the location of the statutory seat or actual administration, which is the central substantive issue resolved by affirming the lower court's decision.

B.2022.108 · sg (Art. 71 StG)

Tax Domicile Determined by Place of Actual Management Over Letterbox Seat

Provision determining unlimited tax liability based on the place of actual management.

B.2022.108 · sg (Art. 71 StG)

Taxation Based on Place of Actual Management Over Formal Seat

This provision, along with Art. 20 Abs. 1 StHG, establishes the legal basis for determining unlimited tax liability based on the place of actual management.

I.1.2020.172.173 · sg (Art. 71 StG)

Unlimited Tax Liability and Disallowed Expenses Upheld

Cited as a legal basis defining when a company is subject to unlimited tax liability based on actual management location.

I.1.2020.172.173 · sg (Art. 71 StG)

Tax Liability and Disallowed Expenses of Foreign-Managed Company

Cited as a legal basis establishing the jurisdiction/tax liability that the court upheld in its final decision regarding the appeal.

I.1.2015.37 · sg (Art. 71 StG)

Corporate Tax Allocation Dispute: Seat vs. Branch Profit Share

Cited as the legal basis for the taxation of legal persons based on seat or actual management.

I.1.2015.37 · sg (Art. 71 StG)

Tax Dispute Over Profit Allocation Between Domicile and Autonomous Branch

Cited as the general rule for tax liability based on location of seat or actual management, relevant to the context of the decision.

I.1.2014.151 · sg (Art. 71 StG)

Corporate Tax Apportionment Appeal Regarding Real Estate Dealer's Allowance

Provision regarding the tax liability of legal entities in St. Gallen, which was confirmed as inapplicable for the claim that the company was not taxable in St. Gallen (order no. 2 implicitly upholds the tax base).

I.1.2014.151 · sg (Art. 71 StG)

Property Dealer's General Expense Allocation Dispute and Tax Jurisdiction

This article establishing tax liability based on domicile/management was part of the context but was not explicitly cited in the dispositive orders.