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