Protection of the Taxpayer in the Information Exchange Procedure

Abstract

Economic globalization and the interdependence of tax authorities highlight the limits of strict national approaches to combating fraud, tax avoidance and evasion. In this context, mutual assistance between tax authorities, in search of direct information to enable the control on the fulfilment of tax obligations by taxpayers, has assumed an increasingly central role. However, the information exchanged through the different stages and tools of administrative cooperation in tax matters should be adequate regarding the various interests involved. On the one hand, those of the States to both exercise their power of taxation as well as fight tax avoidance and evasion; while on the other, those of the taxpayers in the correct use of this instrument to safeguard their rights.