Questão jurídica principal
Whether the administrative law appeal was admissible and the parallel constitutional complaint could be heard
Decisão extraída
The administrative law appeal was admissible under the Tax Harmonization Act; the constitutional complaint was therefore inadmissible.
Fundamentação extraída
The matter fell within Art. 73 StHG and the transitional period in Art. 72 StHG had expired, excluding the constitutional complaint.