Justice, Equality and Tax Law

S. 3661. Introduction

Although measures against tax avoidance and evasion have existed for almost a century, it is only during the last decade that the world has seen global efforts to combat international tax evasion and avoidance. In these last ten years, the Base Erosion and Profit Shifting (hereinafter, “BEPS”) actions have been published, the Inclusive Framework has been installed, new standard on automatic exchange of information have been launched and many countries, even small and developing economies, have joined global initiatives to tackle this problem. At the level of the European Union, regulations such as the Directive on Administrative Cooperation (hereinafter, “DAC”) have also introduced drastic changes in relation to international tax transparency. Therefore, it is undeniable that even today and throughout all these years, there have been great efforts to achieve a much more transparent international tax system. This is because it is understood that a transparent system reduces tax avoidance and evasion, which brings justice and fairness to that system.

During this process, the exchange of information has been consolidated as an indispensable instrument to achieve this obj...