Facts
A. AG declared losses in its tax returns for 2009 and 2010, which were designated as "provisional". The tax administration of the Canton of Zug made various offsetting adjustments in the final assessment decisions. A. AG then submitted "new (final) annual financial statements" and "revised" tax returns for 2009 and 2010, in which it dissolved two items with an effect on profit or loss. This resulted in new tax factors that A. AG asserted. The Appeals Commission and the Administrative Court of Zug dismissed A. AG's objection and appeal. A. AG filed an appeal in public law matters against the judgment of the Administrative Court.Considerations
The Federal Supreme Court states that in accordance with the principle of the binding nature of the commercial balance sheet for the tax balance sheet, balance sheet corrections can always be made up to the final assessment and must be made ex officio, as this corrects a balance sheet item that violates mandatory commercial law provisions. Balance sheet amendments, on the other hand, are only permissible up to the submission of the tax return and in the course of the assessment procedure, in principle only if it becomes apparent that the taxpayer has made…