Shades of transparency DAC6 and the client- attorney privilege Marco Greggi
By: Greggi, Marco
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Material type: 
ArticleSubject(s): DAC 6 | TRANSPARENCIA FISCAL | INTERMEDIARIOS FISCALES | ABOGADOS | CONTRIBUYENTES | DERECHOS | PROTECCION DE DATOS | SECRETO PROFESIONAL | UNION EUROPEA
In:
EC Tax Review v. 32, issue 2, April 2023, p. 67-82Summary: Tax Law has become more and more a data-centric discipline through the years. The struggle against international tax avoidance and evasion has pushed the European union to pass a number of directives regulating the exchange of information and the taxpayers’ duty to disclose information and data concerning their business and investments. The article considers DAC6 (Directive on Administrative Cooperation, Council Directive 2018/822) a qualitative change in this scenario, as it appears to erode the client-attorney privilege. It imposes, for the first time, a duty of transparency to intermediaries such as consultants and (potentially) lawyers which is in collision with fundamental rights, eventually casting a shadow on the due process clause and (indirectly) the rule of law.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141-B/2023/2-3 (Browse shelf) | Available | OP 2141-B/2023/2-3 |
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| OP 2141-B/2023/2 EC Tax Review | OP 2141-B/2023/2-1 Taxing interest in the Debtor State as an Alternative to DEBRA | OP 2141-B/2023/2-2 May a country tax a subsequent restructuring under the Merger Directive? | OP 2141-B/2023/2-3 Shades of transparency | OP 2141-B/2023/2-4 Excise Duty Directive 2020/262 | OP 2141-B/2023/3 EC Tax Review | OP 2141-B/2023/4 EC Tax Review |
Resumen.
Tax Law has become more and more a data-centric discipline through the years. The struggle against international tax avoidance and evasion has pushed the European union to pass a number of directives regulating the exchange of information and the taxpayers’ duty to disclose information and data concerning their business and investments. The article considers DAC6 (Directive on Administrative Cooperation, Council Directive 2018/822) a qualitative change in this scenario, as it appears to erode the client-attorney privilege. It imposes, for the first time, a duty of transparency to intermediaries such as consultants and (potentially) lawyers which is in collision with fundamental rights, eventually casting a shadow on the due process clause and (indirectly) the rule of law.
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