EU Disclosure Regime on Cross-Border Tax Planning Arrangements: Pending Decision Court of Justice of the European Union (ECJ) on Legal Professional Privilege and Constitutionality of the Directive on Administrative Cooperation (DAC6)

On 21 September 2022, the ECJ was asked to determine whether the European disclosure regime for cross-border tax planning arrangements violates the principles of equality, non-discrimination and legal certainty, as well as the right to a private life. Will this eventually result in redesigning the EU DAC6 framework?