Introduction to European Tax Law on Direct Taxation
7. Aufl. 2022
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S. 245I. The Directive on Administrative Cooperation in the Field of Direct Taxation
A. Background and History
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The first Directive on mutual assistance in the assessment of taxes in the field of direct taxation entered into force in December 1977. The Directive was drafted with a view to providing for an efficient exchange of information between the Member States in order to counter new forms of tax evasion and avoidance, which are increasingly assuming a multinational character. This first Directive provided a framework for exchange of information on request only and was revised several times.
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In 2003, the Council adopted Directive 2003/48/EC (hereinafter: the Savings Directive), which was aimed at effective taxation of cross-border interest payments in the State of residence of individuals. This ultimate aim was achieved by introducing obligatory and automaticexchange of information at regular intervals for the first time.
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In 2011, provoked by successive financial crises, the Council adopted a completely new Directiveon Administrative Cooperation in the field of taxation (hereinafter: “DAC”). The DAC improved effectiveness in many areas: in particular, mandatory automatic exchange was intr...