Facts

The spouses [A.A.] and [B.A.] (taxpayers, appellants, represented by a fiduciary company) had their tax domicile in [U.] (AG) in the 2017 tax period. On 14 June 2019 they asked the municipality of residence to remit the cantonal and municipal taxes 2017, which had become final, to the extent of the still outstanding Fr. 2'712.30 (originally Fr. 6'626.80), plus default interest. The Municipal Council of [U.] rejected the request on 10 September 2019.

The taxpayers appealed to the Special Administrative Court of the Canton of Aargau, Tax Division, and asserted a monthly expenditure surplus of Fr. 674.-- based on their calculation of the subsistence minimum. The court dismissed the appeal in decision 3-RB.2019.16 of 21 April 2020. It stated that the taxpayers had debts totalling Fr. 53'721.-- (private loan Fr. 36'500.--; consumer credit with a financial institution Fr. 17'221.--). A full waiver of the claim by the private lender was proven, but no such waiver by the financial institution existed. An insurance benefit of Fr. 2'666.35 had been credited to the account with the financial institution, so the required symmetry of sacrifice was lacking. In addition, from 2017 onward the taxpayers had made contributions to pillar 3a of Fr. 3'100.-- as well as voluntary payments of Fr. 700.--; the husband's disability pension did not change this. In any event, the requirements for a tax remission were not met.

By submission of 22 May 2020, the spouses lodged with the Federal Supreme Court a submission designated as a 'Staatsrechtliche Beschwerde' (public law appeal). They requested the annulment of the decision and the calculation of the remission based on their own figures. They essentially complained that the lower court had not seriously investigated the reason for taking out the loan; that the contribution to pillar 3a was a one-time payment made before the financial difficulties arose; and that, due to their marriage in 2017, a 'marriage penalty' of Fr. 217.-- arose.

The division president, acting as instruction judge, dispensed with instructional measures, in particular with an exchange of written submissions.

Considerations

The submission is to be treated as a subsidiary constitutional complaint, since the ordinary appeal in public law matters is not available in the area of remission (Art. 83 lit. m FSCA). Through the subsidiary constitutional complaint, only violations of constitutional individual rights may be asserted (Art. 116 FSCA). The qualified obligation to state complaints and provide reasons applies (Art. 117 in conjunction with Art. 106 para. 2 FSCA); purely appellatory criticism is not sufficient.

The lower court was solely required to examine whether the requirements for a tax remission under § 230 para. 1 StA/AG were met. According to settled practice, this provision confers no legal entitlement to deferral or remission. The taxpayers are not affected in any legally protected interests by any possible arbitrary interpretation or application of cantonal law (Art. 115 lit. b FSCA). They therefore lack standing to raise complaints concerning the remission issue.

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