Exchange of Information on Request: Whenever, Wherever? Shakira’s (and Berlioz’s) Right to Judicial Review of the Foreseeable Relevance Standard

The author analyses the negative impact of the Global Forum peer review of Luxembourg on taxpayers’ right of judicial review of the foreseeable relevance of incoming requests for information. Recent case law at the European and national level is analysed, leading to the conclusion that such review is compulsory in EU Member States, which could affect the future direction of the Global Forum in the matter of taxpayer rights regarding the exchange of information on request.