The Limits to the Participation of the Taxpayer in Tax Dispute Resolution Procedure Under the Dispute Resolution Directive

Abstract

This article intends to analyse whether the participation of a taxpayer can be further enhanced in tax dispute resolution under Directive (EU) 2017/1852. As a response to increasing arguments in support of a taxpayer’s participation, the analysis engages with broader legal concepts and human rights law with a specific focus on the right to a fair trial and normative standards. With this distinction of arguments in mind, the article outlines policy options of increasing the participation of the taxpayer in the procedure. Tax dispute resolution, MAP, arbitration, Directive (EU) 2017/1852, taxpayer’s participation, legitimate interest, right to a fair trial, Standing Committee