Abstract
The aim of this article is to analyse a form of administrative cooperation, which is the mandatory automatic exchange of information in the field of tax interpretations, concerned in Action 5 of the BEPS Project (Base Erosion and Profit Shifting) and introduced in Council Directive 2015/2376 (EU) of 8 December 2015, amending Directive 2011/16/EU with regard to mandatory automatic exchange of information in the field of taxation – as regards a taxpayer’s rights and – in a broader context – those of an entity, to whom the individual interpretation concerns.
Highlights
The BEPS Project, developed in 2013 at the Forum on Harmful Tax Practices, is the answer of OECD as well as countries united within the G20 to the problem of both tax avoidance and evasion, which affect the economic interests of numerous countries
Cross-border tax avoidance, aggressive tax planning as well as harmful tax competition have been noticed at the EU level, as the Directive 2011/16/EU1 on administrative cooperation in the field of taxation has been in force for the recent years
The directive has been amended for a number of times with regard to automatic information exchange; its objective applicability scope has been extended, and duties related to accounting have been introduced[2]
Summary
M The aim of this article is to analyse a form of administrative cooperation, which is the mandatory automatic exchange of information in the field of tax interpretations, concerned in Action 5 of the BEPS Project (Base Erosion and Profit Shifting) and introduced in Council Directive 2015/2376 (EU) of 8 December 2015, amending Directive 2011/16/EU with regard to mandatory automatic.
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