61However, the Court arrived at that interpretation on the ground that that person holding information, who is distinct from the taxpayer concerned by the investigation giving rise to the decision ordering that information be provided, is unable to access a court without first infringing that decision by refusing to comply with the order it contains and thus being subject to the penalty attached to non-compliance with that decision (judgment of 6 October 2020, État luxembourgeois (Right to bring an action against a request for information in tax matters), C‑245/19 and C‑246/19, EU:C:2020:795, paragraph 68).
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