- ECJ validates several provisions of DAC6
- Reporting obligation under DAC6 not limited to corporate taxes
- Validity of directive upheld in light of principles of equal treatment and non-discrimination
- Precision and clarity of terminology in directive provisions not questioned
- Interference with private life of intermediary and taxpayer defined sufficiently
- Legal professional privilege exemption applies only to lawyers practicing in other Member States
- Reporting obligation on intermediaries and taxpayers considered proportionate and justified
- Unfavourable judgement for tax professionals in ETAF Member States
- CJEU refused to substitute obligation to notify with obligation to report for tax professionals without court representation authorization
Source: etaf.tax
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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