Facts
The appellant, Dr. [A.A.] , is married to [B.A.] née [S.] . The wife moved to [T.] /BE with their three sons from abroad in 2008 and registered in [V.] /SG in 2012. The husband claims to have lived in [W.] (GB) and later in [Z.] (DE) and [Y.] (GB) since 2012. However, the tax authority of the canton of St. Gallen assumed that the husband had his tax domicile in [V.] /SG.
The lower court, the Administrative Court of the canton of St. Gallen, Division III, dismissed the husband's appeal and confirmed the finding of the tax authority. The husband then appealed to the Federal Supreme Court.
Considerations
The Federal Supreme Court examined the appeal and came to the conclusion that the husband's tax domicile was in [V.] /SG during the tax periods 2012 to 2017. The lower court had established that the husband had lived in the wife's apartment in [V.] /SG and that the wife and son had moved to [V.] /SG on October 22, 2012.
The Federal Supreme Court found that the lower court had rightly assumed that the husband's domestic domicile was established with near certainty. The collected legally relevant facts spoke a clear language, indicating that the husband had lived in the joint apartment in [V.] /SG.
The Federal…