Questão jurídica principal
Whether the Federal Supreme Court had jurisdiction over the appeal against interim orders in this tax assistance matter.
Decisão extraída
No. Because the Federal Administrative Court has final jurisdiction in this subject area, the federal appeal was unavailable, and the same applied to the challenged interim orders.
Fundamentação extraída
Jurisdiction under Art. 94 BGG presupposes appealability in the underlying subject matter. In international tax assistance, such federal appeals are excluded by Art. 83 lit. h BGG; the court also rejected reliance on the data protection argument to create jurisdiction.