
DAC6 and the professional secrecy of tax advisers
Directive (EU) 2018/822, of the Council, of May 25, 2018, imposes the obligation on tax intermediaries to declare those international tax operations that show signs of aggressive tax planning, an obligation that collides head-on with the right to respect for communications between lawyer and client. That is why the CJEU has recently declared that this notification obligation will no longer be necessary in the case of lawyers.