Facts
The tax administration of the canton of VS determined the main tax domicile of taxpayers [A.] and [B.] as of the 2016 tax period in [U.] /VS. The taxpayers appealed, but it was rejected. The tax appeals commission of the canton of VS overturned the appeal decisions and found that the taxpayers' center of life was in [V.] /TI. The tax administration of the canton of VS appealed to the Federal Court.
The taxpayers managed a five-star hotel in [U.] /VS from 2014 to 2018 and lived in a rented apartment and later in a hotel room during this time. In their free time, they regularly returned to [V.] /TI, where they owned a 4.5-room apartment.
Considerations
The Federal Court examined the appeal and found that the tax appeals commission of the canton of VS had wrongly assumed that the taxpayers' center of life was in [V.] /TI. The taxpayers had not proven that they regularly returned to [V.] /TI on weekends, and their connections to [V.] /TI were not sufficient to assume their center of life was there.
The Federal Court found that the taxpayers had a center of life in [U.] /VS, as they were active there as co-directors of a five-star hotel and owned an apartment. The fact that they lived in a hotel room did not change their center of life in [U.] /VS.
The…