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Sabou v Financni reditelstvi pro blavni mesto Prahu

Exchange of information request

In Sabou v Financni reditelstvi pro blavni mesto Prahu (C-276/12) the taxpayer was a professional footballer resident in the Czech Republic who was challenging an assessment denying him the right to deduct various expenses he claimed to have incurred during professional trips in several European countries.

The Czech court had referred the case to the CJEU for a preliminary ruling. The European Court had to decide whether the taxpayer should have been informed of requests for information sent by the Czech tax authorities to the tax authorities of the relevant European countries and if so whether he should have been consulted in the drafting of those requests or in the questioning of witnesses.

The CJEU answered each of the above questions in the negative. It pointed out that national tax authorities were under no obligation to inform taxpayers of enquiries carried out in...

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