article intends to analyse whether the participation of a taxpayer can be
further enhanced in tax dispute resolution under Directive (EU) 2017/1852. As a
response to increasing arguments in support of a taxpayer’s participation, the
analysis engages with broader legal concepts and human rights law with a
specific focus on the right to a fair trial and normative standards. With this
distinction of arguments in mind, the article outlines policy options of
increasing the participation of the taxpayer in the procedure.