DAC 6 and the European Rejection of Professional Secrecy Beyond That of Lawyers: The CJEU Judgment of 29 July 2024

EC Tax Review Kluwer Law International


The article analyzes the July 29, 2024 judgment by the Court of Justice of the European Union (CJEU) concerning Directive DAC 6, which obliges intermediaries to report certain cross-border tax arrangements. The Court ruled that only lawyers can invoke legal professional privilege to avoid disclosing information to other intermediaries. Other professionals, such as notaries or accountants, even if bound by national professional secrecy laws, are excluded from this exemption.

EC Article TAX REVIEW 2025–2