Opinion of Advocate General Wathelet delivered on 10 January 2017.

Berlioz Investment Fund SA v Directeur de l'administration des contributions directes.#Request for a preliminary ruling from the Cour administrative (Luxembourg).#Reference for a preliminary ruling — Directive 2011/16/EU — Administrative cooperation in the field of taxation — Article 1(1) — Article 5 — Request for information sent to a third party — Refusal to respond — Penalty — Concept of ‘foreseeable relevance’ of the information requested — Review by the requested authority — Review by a court — Scope — Charter of Fundamental Rights of the European Union — Article 51 — Implementation of EU law — Article 47 — Right to an effective judicial remedy — Access of the court and of the third party to the request for information sent by the requesting authority.#Case C-682/15.
Opinion of Advocate General Wathelet delivered on 10 January 2017