Judgment_paragraph 47 · Eamonn Donnellan v The Revenue Commissioners (C-34/17)

47By contrast, as the Court has previously held, it cannot be ruled out that the requested authority may, exceptionally, decide not to grant its assistance to the applicant authority. Enforcement of the request for recovery of the claim may thus, inter alia, be refused if it is shown that such enforcement is liable to be contrary to the public policy of the Member State of the requested authority (see, with regard to Article 12 of Directive 76/308, to which, in essence, Article 14 of Directive 2010/24 corresponds, judgment of 14 January 2010, Kyrian, C‑233/08, EU:C:2010:11, paragraph 42).