CFE is commenting on the proposal for a Fair Taxpayer Label for two reasons:
– Tax advisers´ task is to ensure the respect of taxpayers´ rights. Depending on which criteria a taxpayer label would be based and by whom it would be awarded, there may be repercussions for the protection of taxpayer rights.
– Assessments for a taxpayer label (in the following: audits) are a potential business for tax advisers and other operators, although we estimate that the economic relevance of such audits for tax advisers would remain limited;
CFE is not in principle in favour or against introducing a voluntary taxpayer label, but would like to be sure that a taxpayer label, if introduced, is done in a way that does not harm taxpayers, e.g. by creating inequality among taxpayers, by preventing taxpayers from making use of their rights under tax or procedural laws, or by distorting competition through sending misleading messages. As shown in the following, a lot of issues need to be considered and a number of concerns remain. CFE would be strictly against any mandatory taxpayer label.
In the following, the term “taxpayer label” is used for a voluntary label awarded to taxpayers in EU or other European countries, relying on fairness or other criteria.