Taxpayers’ Rights in the Expanding Universe of Criminal and Administrative Sanctions: A Fundamental Rights Approach to Punitive Tax Law Following the OECD/G20 Base Erosion and Profit Shifting Project

This article discusses the current trend towards the expansion of states’ punitive powers, identifies and traces the phenomenon in tax law, and discusses the effect that this particular approach to criminal and administrative sanctions has in the definition and the scope of taxpayers’ rights regarding punitive matters.