Questão jurídica principal
Whether the cantonal remand decision was an appealable final decision under Art. 90 BGG
Decisão extraída
The remand decision was only an interlocutory decision because the tax office still had to clarify facts and exercise discretion; no exception made it immediately appealable.
Fundamentação extraída
A remand is final only if the lower authority has no decision-making room and must merely implement the higher court's instructions. Here, further investigation was required on whether and to what extent rent payments from subtenants accrued, which could affect the deemed dividend assessment.