Kernrechtsfrage
Whether the appeal against the remand judgment was admissible as a separately challengeable interim decision.
Extrahierter Entscheid
The remand decision was separately appealable because it could force the ESTV into an erroneous discretionary assessment causing irreparable legal harm.
Extrahierte Begründung
The remand required more than technical implementation and could not later be effectively challenged; Art. 93(1)(a) BGG was satisfied.