
doi: 10.59403/2seadra
handle: 21.11116/0000-0012-8C4E-8
This article examines the tension between taxpayer rights and the automatic exchange of information (AEOI), focusing on recent Swiss case law. AEOI, promoted by the OECD and G20, enables large-scale cross-border tax data transfers, raising concerns over privacy, data protection and legal remedies. In decisions 2C_780/2020 and 2C_946/2021, the Swiss Federal Supreme Court clarified that reporting financial institutions ensure data accuracy, while the Federal Tax Administration serves as a technical conduit. Also, upholding multilateral trust, the Court relied on OECD peer reviews and partner states’ commitments, yet dismissed broader rights concerns. An analogy with asylum law highlights the heavy evidentiary burden on challengers.
| selected citations These citations are derived from selected sources. This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically). | 0 | |
| popularity This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network. | Average | |
| influence This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically). | Average | |
| impulse This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network. | Average |
