Kernrechtsfrage
Whether the new request to determine withholding tax claims was admissible before the Federal Court.
Extrahierter Entscheid
The request was inadmissible because it was raised for the first time before the lower appellate court and fell outside the dispute's subject matter.
Extrahierte Begründung
A claim not addressed below and introduced only at a later stage cannot expand the scope of the case before the Federal Court.