Facts
The tax administration of the canton of Thurgau appealed against the judgment of the Administrative Court of the canton of Thurgau of 5/26 June 2013, which had established that [A.] did not have a tax domicile in Switzerland from 1 March 2009 to 31 August 2011. [A.] had worked for [B. AG] in Saudi Arabia during this period under a foreign employment contract and had kept his rented apartment in Switzerland in order to spend his holidays there during his stay abroad.
The lower court had considered the evidence of the relocation of the domicile as proven on the basis of an overall assessment of the objective, external circumstances. The appellant argued that the relocation of the domicile presupposes the final dissolution of ties to the previous domicile and that [A.] had kept his apartment in Switzerland in order to spend his holidays there during his stay abroad.
Considerations
The Federal Court dismissed the appeal and confirmed the judgment of the lower court. It stated that the tax domicile of a person is where the center of their life interests is actually located. The intention of permanent residence does not require that the taxpayer remains at a location forever or for an indefinite period, but it is sufficient to make the place of residence the center of life circumstances for the time being and to give it a certain stability.
The Federal Court found that the lower court had made an overall assessment of all objective, external circumstances to determine [A.] 's domicile during the period from 1 March 2009 to 31 August 2011. It stated that the appellant had not clearly and in…