Abstract
This article addresses some aspects of the impact of the fairness requirement on international administrative cooperation for the cross-border recovery of taxes and the influence of the case law of the European Court of Justice (ECJ) in this area. This case law relates to the interpretation of EU law in this field (currently the Recovery Directive (2010/24)). Council Directive 2010/24 of 16 March 2010 concerning mutual assistance for the recovery of claims relating to taxes, duties and other measures, OJ L 84 of 31 March 2010, p. 1, Primary Sources IBFD [hereinafter Recovery Directive (2010/24)]. This directive has effect from 1 January 2012. It is, however, also relevant for the interpretation and application of other international agreements relating to mutual assistance in the recovery of taxes.
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