Source Curia
AG Opinion
Article 8a (5) of Council Directive 2011/16 / EU of 15 February 2011 on administrative cooperation in the field of taxation and repealing Directive 77/799 / EEC, as amended by Directive (EU) ) 2018/822 of 25 May 2018, which obliges the lawyer acting as an intermediary who, citing his professional secrecy, is exempted from the obligation to submit information to notify without delay to another intermediary the obligations to submit information pursuant to paragraph 6 of that Article, shall not infringe the right to respect for privacy enshrined in Article 7 of the Charter of Fundamental Rights of the European Union;provided that the lawyer’s name is not disclosed to the tax authorities in connection with the performance of the obligation to provide information laid down in the second subparagraph of Article 8a (9) and (14) of that Directive.
