The Taxpayer’s Dilemma: Navigating Mandatory Disclosure under DAC6 Between Compliance and Criminal Liability. Rethinking Nemo Tenetur in the Context of EU Exchange of Information
The rule of law is a cornerstone of modern constitutional democracies, not merely as a safeguard against tyranny and arbitrariness, but as a principle inherently connected to human rights, legal certainty, and democratic accountability. Within the European Union, recent years have witnessed growing tensions between the expansion of regulatory frameworks and the preservation of individual guarantee