Facts
The appellant, a Swiss citizen born in 1957, married in 2010 and cancelled his registration in 2010 to move to Thailand. His wife remained in Switzerland and worked here. The municipality of [M.] , where the appellant lived, requested the determination of the appellant's tax domicile in [M.] , as it believed that the cancellation of registration in Thailand was only intended to prevent taxation of the IV pension.
The cantonal tax administration determined the appellant's main tax domicile in [M.] until 31 December 2010 and in Thailand from 1 January 2011. The municipality appealed and the cantonal tax administration determined the appellant's main tax domicile in [M.] . The appellant appealed to the Tax Appeals Commission of the Canton of Valais, which dismissed his appeal.
The appellant appealed to the Federal Court and requested the annulment of the contested decision. The tax administration and the Tax Appeals Commission of the Canton of Valais requested the dismissal of the appeal.
Considerations
The Federal Court examined the admissibility of the appeal and found that the appellant had filed the appeal in a timely and formal manner. The court applied federal law ex officio and examined the alleged grievances.
The court found that the appellant had not provided evidence of establishing a new foreign residence. The lower court had found that the appellant and his wife had spent most of their time together in Switzerland and that the appellant had a large and intact circle of…