The exchange of information regime under the DAC, like Art 26 OECD MC, is based on the foreseeable relevance concept. The original DAC did not make clear whether group requests would meet these criteria. This question was only recently answered by the CJEU in the État luxembourgeois case. Stefanie Geringer analyzes the findings in the court’s decision and particularly discusses their relationship with the recent amendments due to DAC 7 as well as with related OECD documents.
