The Court of Justice of the European Union (CJEU) has held that the EU DAC6 Directive violates the right to respect for communications between a lawyer and his or her client.
The DAC6 Directive provides that all intermediaries involved in potentially aggressive cross-border tax planning (arrangements which could lead to tax avoidance) must be reported to the competent tax authorities.
A Member State may grant intermediaries a waiver from that obligation where it would breach legal professional privilege. In such circumstances, lawyer-intermediaries must notify any other intermediary, or the relevant taxpayer, of their reporting obligations.
Source TP News
