Opinion of Advocate General Saugmandsgaard Øe delivered on 15 July 2021.#European Commission v Kingdom of Spain.#Failure of a Member State to fulfil obligations – Article 258 TFEU – Free movement of capital – Obligation to provide information concerning assets or rights held in other Member States of the European Union or the European Economic Area (EEA) – Failure to comply with that obligation – Limitation – Penalties.#Case C-788/19.