Facts
The spouses A.A. and B.A. have their tax domicile in U./SH and acquired a condominium unit in Italy in 2017 for EUR 380'000.-. The tax administration of the canton of Schaffhausen valued the property at 80% of the purchase price (Fr. 355'710.-) and set the self-occupancy value at 5.0% of the wealth tax value (Fr. 17'785.-). The taxpayers requested a correction, as they assumed a wealth tax value of 60% of the purchase price (Fr. 270'000.-) and a self-occupancy value of Fr. 305.- (2017) and Fr. 10'000.- (2018), respectively.
The cantonal remedies remained unsuccessful, and the taxpayers appealed to the Federal Court with a complaint in public law matters.
Considerations
Legal basis: The valuation of a foreign-located property for Swiss tax purposes is governed by the Federal Act on Direct Federal Taxation (DFTA) and the Tax Harmonization Act (DTHA). The DFTA regulates the taxation of properties abroad, while the DTHA governs the harmonization of direct taxes of the cantons and municipalities.
Valuation of the property: The tax administration of the canton of Schaffhausen valued the property at 80% of the purchase price, which, according to the Federal Court, is not objectionable. The taxpayers were unable to prove that the actual market value of the property was lower.
Self-occupancy value: The self-occupancy value was set by the canton of Schaffhausen at 5.0% of the wealth tax value, which is federally unobjectionable. The taxpayers were unable to prove that the actual self-occupancy value…