Questione giuridica chiave
Whether the appellant, as beneficial owner rather than account holder, had standing to appeal against the tax assistance order.
Decisione estratta
No. The complaint did not sufficiently show a specific legally protected connection giving him standing; indirect affectedness as beneficial owner was insufficient.
Motivazione estratta
The Court relied on its settled case law that standing in international assistance matters lies with the account holder, not the beneficial owner, unless exceptional circumstances exist, such as the account-holding company no longer existing. The appellant failed to address this burden of reasoning under Art. 42 BGG.