Resumo

LEONETTI, JUAN EDUARDO. THE ROLE OF TAXPAYERS, RESPONSIBLE AND THIRD PARTIES IN THE EXCHANGE OF INFORMATION BETWEEN TAX ADMINISTRATIONS. Díkaion [online]. 2012, vol.21, n.2, pp.511-529. ISSN 0120-8942.

Analyzing information exchange agreements signed between different tax administrations, clearly reveals that - except for tax or professional secrecy- tax payers and even third parties that can be affected with these proceedings have no voice in the system. There are but slim chances to participate and in almost every case, these chances are inefficient. It is not surprising then that these taxpayers, responsible or third parties are reluctant - more than usual- when having to deal with the requirements of the tax administration, without forgetting that parties under obligation with the tax administration are so required by the legal regime from where they declare their income. This paper stresses the importance of balancing the tax administration's rights to access information and the unrestricted respect of the taxpayers' and third parties' rights in a State of law; it is based on analyzing the agreement paradigm proposed as a model by the Organization for Economic Co-Operation and Development.

Palavras-chave : International tax paying system; information exchange.

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