Question juridique clé
Whether the German request for mutual legal assistance in a tax-fraud investigation was sufficiently substantiated to justify assistance.
Solution extraite
The request, together with the later submitted evidence, provided sufficient concrete suspicion of tax fraud; the higher substantiation threshold was met.
Motifs extraits
The Court held that the request did not need to prove the charges conclusively. The supplementary witness statements and documents, read as a whole, supported rather than contradicted the factual account and did not immediately dispel the suspicion.