Belgium Constitutional Court Issues Judgment on DAC6 Law Including the Annulment of Certain Restrictions on Invoking Professional Privilege

The Constitutional Court of Belgium has issued Judgment No. 103/2022 of 15 September 2022 concerning the Law of 20 December 2019, which transposed Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) on the exchange of reportable cross-border arrangements. The judgment addresses several different actions seeking the total or partial annulment of the DAC6 Law in Belgium.

One of the key aspects of the judgment is the annulment of four similar provisions (under different tax/fee laws) concer…