Assignment of one-time payments in the event of subsequent ordinary taxation

Facts

[A.X.] and [B.X.] moved from abroad to the Canton of Basel-Stadt on January 15, 2008, and from there to [Y.] /BL on March 1, 2008. [A.X.] earned a gross employment income of CHF 148,890.-- in the 2008 tax period and received one-time payments totaling CHF 23,600.-- in January 2008. The tax authorities of the Cantons of Basel-Stadt and Basel-Landschaft assessed the taxpayers for the direct federal tax and the cantonal taxes for 2008. The issue was which canton the one-time payments should be assigned to.

Considerations

The Federal Supreme Court decided that the one-time payments totaling CHF 23,600.-- are to be assigned exclusively to the Canton of Basel-Stadt in accordance with Art. 38 para. 4 StHG. The regulation in Art. 38 para. 4 StHG is to be interpreted in such a way that the respective canton of residence or stay has the exclusive taxation authority in accordance with the tax liability in this canton. The same applies to the…