Legal Protection of Tax Debtors in Respect of Cross-Border Use of Precautionary Measures to Guarantee Tax Recovery

The ECJ recently issued two decisions on cross-border administrative assistance for the recovery of taxes (Heavyinstall (Case C-420/19) and Silcompa (Case C-95/19)). This new line of case law not only answers certain questions regarding the interpretation of the EU Recovery Directive (2010/24), but also raises new questions concerning, in particular, the legal protection of the taxpayer in the face of cross-border requests for precautionary measures to guarantee the recovery of non-final tax claims.