Public international law recognizes rights to non-state actors. In tax matters, these include taxpayers and other private persons involved in the levying of tax. Their fundamental rights are human rights, which must be effectively protected even when there is a general interest of the community to the collection of tax. This Article contains a comprehensive worldwide analysis of such rights and addresses the different issues that arise—in national and cross-border situations—in connection with tax procedures and sanctions. The Article puts forward various innovative proposals that secure an effective ex ante protection on the basis of the general principles of law common to the various legal systems and the specific principles relevant to tax matters.

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