Introduction: institutional choice and constitutional principle The line of case-law initiated by the Court of Justice of the European Union (CJEU) with the Berlioz ruling in 2017 has been hailed as a major development in…
1. Introduction This post aims to critically examine the evolution of the application of Article 47 of the Charter in certain tax cases. ‘Tax cases’ is a general term that comprises two vast areas of…
Introduction Foreseeable relevance is important for tax treaties and European Union Law, but its concept is defined by neither of them. Nevertheless, it has been an object of interpretation, also by the Court of Justice…
1. Introduction The EU Directive on Administrative Cooperation (DAC), enacted in 1977 and – as a standard – most recently re-adopted in 2011, has been amended several times with its scope of application broadened over…
The concept of “foreseeable relevance” is an essential element of the standard of transparency in tax matters. It has experienced significant changes in its scope and conceptual interpretation during the last few years to ensure…