Question juridique clé
Whether the subsidiary constitutional complaint is admissible against the refusal of remission of direct federal tax.
Solution extraite
No. The complaint is inadmissible because the taxpayer lacks a legally protected interest, as there is no entitlement to remission of direct federal tax.
Motifs extraits
Subsidiary constitutional complaint requires a legally protected interest under Art. 115 lit. b BGG. In remission matters, only arbitrariness can typically be invoked, but standing for an arbitrariness claim exists only where a norm confers an enforceable right or protective interest. Art. 167 Abs. 1 DBG is discretionary and grants no legal claim.