Kernrechtsfrage
Whether refusal to grant VAT payment facilitation had to be issued as an appealable administrative decision
Extrahierter Entscheid
No. In VAT law, outside judicial debt-rescheduling proceedings, payment facilitation is only an individual discretionary administrative accommodation and does not have to be issued as an appealable decision.
Extrahierte Begründung
The VAT system deliberately omits a statutory right to deferral or instalments; the refusal does not create or deny an enforceable new legal position and is part of non-justiciable collection management.