Judgment_paragraph 82 · État luxembourgeois v B and Others (C-245/19, C-246/19)

82A correction or adjustment decision constitutes an act in relation to which the taxpayer concerned must have a right to an effective remedy, which presupposes that the court hearing the dispute has jurisdiction to consider all the issues of fact and of law relevant for resolving that dispute, as alluded to in paragraph 66 above, and, in particular, to verify whether the evidence on which that act is based has been obtained or used in breach of the rights and freedoms guaranteed to the person concerned by EU law (see, by analogy, judgment of 17 December 2015, WebMindLicenses, C‑419/14, EU:C:2015:832, paragraphs 87 to 89).