Questão jurídica principal
Whether the appeal could be treated as administrative judicial review rather than a constitutional complaint for cantonal tax-law issues during the StHG transitional period
Decisão extraída
For alleged arbitrary application of cantonal tax law in the transitional period, only constitutional complaint was available; the filing was treated accordingly where its reasoning met the requirements.
Fundamentação extraída
Because the contested period fell within the eight-year harmonization transition, review of cantonal law under Art. 7 canton tax law was not open by administrative appeal. The Court therefore requalified that part of the filing as a constitutional complaint, subject to the pleading requirements.