July 31
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Trajan Shipley
3rd June 2021
Justice & Litigation Tax

AG Kokott: designating taxpayers by mere reference to their shareholder status fulfils identification requirements under DAC

Advocate General Kokott delivered her Opinion in État luxembourgeois (C-437/19) today, advising the Court of Justice to rule that, under Article 20(2)(a) of the Directive on Administrative Cooperation (2011/16) (DAC), its identification requirements are complied with when, in a request for information, the authority designates the taxpayers to which the request relates simply by referring to their status as shareholders and beneficial owners of a company.

In the Advocate General’s view, a request for information may relate to a group of unidentified persons whose identity is ascertainable from their status as shareholders and beneficial owners of a legal person. However, the requesting Member State must show why there is reasonabl


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