Post by account_disabled on Dec 31, 2023 4:39:05 GMT -5
Ahis obligation to provide some information in the context of the execution by the competent authority of the requested member state of which he is a resident of a request for information formulated by another member state which would have no justification in terms of the real fiscal purpose so that in the present case there would be no legitimate purpose and that would be to obtain information that would not be predictably relevant to the tax case in question If the application of the Charter is confirmed in this case the right to an effective remedy and a fair trial as enshrined in Article of the Charter requires without the first paragraph of Article of the.
Charter allowing the provision of some restrictions Country Email List so that the competent national court has substantive jurisdiction and thus the jurisdiction to control at least by way of exception the validity of a decision ordering the provision of information adopted by the competent authority of a member state in within the framework of the execution of a request for the exchange of information submitted by the competent authority of another member state in particular under.
Directive in the context of the action brought by the third party holder of information addressee of this decision ordering the provision of information and directed against a decision to establish a pecuniary administrative sanction due to the nonfulfilment imputed to this litigant of the obligation of collaboration that he has in the execution of the request in question If the application of the Charter in this case is confirmed Article and Article of Directive must taking into account on the one hand the parallelism with the standard of foreseeable relevance arising from the Model Tax Convention of the Organisation for Economic and wealth and on the other hand the principle of loyal cooperation provided for in Article.
Charter allowing the provision of some restrictions Country Email List so that the competent national court has substantive jurisdiction and thus the jurisdiction to control at least by way of exception the validity of a decision ordering the provision of information adopted by the competent authority of a member state in within the framework of the execution of a request for the exchange of information submitted by the competent authority of another member state in particular under.
Directive in the context of the action brought by the third party holder of information addressee of this decision ordering the provision of information and directed against a decision to establish a pecuniary administrative sanction due to the nonfulfilment imputed to this litigant of the obligation of collaboration that he has in the execution of the request in question If the application of the Charter in this case is confirmed Article and Article of Directive must taking into account on the one hand the parallelism with the standard of foreseeable relevance arising from the Model Tax Convention of the Organisation for Economic and wealth and on the other hand the principle of loyal cooperation provided for in Article.