61In relying without further explanation on that risk, the defendant in the main proceedings has not enabled the Court to assess the implications of that argument when it has not been claimed that that risk could not have been avoided through the application of Council Directive 77/799/EEC of 19 December 1977 concerning mutual assistance by the competent authorities of the Member States in the field of direct taxation (OJ 1977 L 336, p. 15), as amended by Council Directive 2006/98/EC of 20 November 2006 (OJ 2006 L 363, p. 129), in force at the time (see, also, judgment of 24 February 2015, Grünewald, C‑559/13, EU:C:2015:109, paragraph 52).
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