Cross-Border Tax Recovery Assistance and the Fundamental Rights of the Tax Debtor

Administrative arrangements for cross-border tax recovery assistance generally focus on ensuring and facilitating the recovery of taxes in an international context. ECJ case law, although limited in this area, confirms the need to focus on legal protection of the fundamental rights of tax debtors. This note describes how this principle may influence the use of the EU Mutual Assistance Recovery Directive (2010/24), as well as other legal instruments for tax recovery assistance.