Ensuring Effective Taxpayer Remedies for Breaches of Confidentiality in Relation to Tax Treaties
Journal
Country
European Union; International; OECD
Published Date
Issue
Bulletin for International Taxation 2020 (Volume 74), No. 11
Document
In this article, the author considers the problems associated with taxpayers’ remedies for breaches of confidentiality in relation to the exchange of information under tax treaties. Within this context, the author proposes a sui generis arbitration clause as a solution to these issues.