81Furthermore, a decision, of the same sort as those at issue in the main proceedings, ordering that information be provided is adopted during the preliminary stage of the investigation concerning the taxpayer in question, during which information relating to the tax situation of that taxpayer is gathered and which does not require an exchange of views and arguments. Indeed, only the last stage of that investigation, which begins with the sending of a proposal for correction or adjustment to the taxpayer concerned, (i) is a contentious stage meaning that that taxpayer is able to exercise his or her right to be heard (see, to that effect, judgment of 22 October 2013, Sabou, C‑276/12, EU:C:2013:678, paragraphs 40 and 44) and (ii) is likely to lead to a correction or adjustment decision, addressed to that taxpayer.
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