Blueprint for Individual Income Taxation Reform in a Globalized World

BIIT
This book explores the need for comprehensive individual taxation reform in a globalized world, addressing key challenges such as labour mobility, digital work and tax competition.

Why this book?

This book presents the proceedings from the inaugural Academic Tax Conference (ATC), held in Amsterdam on 16-17 May 2024. The conference, centred on the theme “Blueprint for Individual Taxation Reform in a Globalized World,” brings together leading scholars and practitioners to explore critical issues in personal income taxation.

While corporate income taxation has long dominated international tax discussions, individual taxation remains underexplored in the global policy arena. Recent developments, including the United Nations’ focus on high-net-worth individuals, signal a shift towards prioritizing personal income taxation on the international stage. However, comprehensive reform addressing the fundamental aspects of individual taxation is still absent. This book seeks to address this gap by examining the pressing need to include personal income taxation in global tax discussions, particularly in light of increased labour mobility, digital work models and growing tax competition between jurisdictions.

The book is structured into six parts, grouping chapters by related themes, while offering diverse perspectives and conclusions. Part I examines tax nexus criteria, exploring how globalization and digitization challenge traditional principles of residence, source and citizenship, while considering redistributive tax policies. Part II focuses on differentiated tax liabilities for mobile individuals, using game theory to analyse jurisdictional competition and proposing a framework for assessing harmful tax regimes, similar to corporate tax standards. Part III delves into tax treaties, addressing the complexities of determining tax residence and proposing new taxing rights for employment and service income through withholding taxes. Part IV discusses the potential justification and design of an EU personal income tax based on citizenship, exploring possible models and their challenges. Part V tackles cross-border philanthropic giving, suggesting reforms to overcome its national limitations. Finally, part VI investigates the taxation of pension income in cross-border situations, including EU efforts to harmonize pension tax policies.

This book not only provides a theoretical foundation for understanding the current landscape but also serves as a practical guide for shaping future reforms in personal income taxation in an increasingly interconnected world.

This book is part of the Academic Tax Conference Series

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Author(s)/Editor(s)

Author(s): David G. Duff, Jean-Philippe Van West, Eleni De Becker, Evelien Timbermont, Giulia Mahlig, Takayuki Nagato, Giorgio Beretta, Rosa Freitas Soares, Sonali Walpola, John Minas, Karen Stark, Savannah-Lee Correia Da Silva, Alison Futter, Ricardo García Antón, Martha Caziero, Giedre Lideikyte Huber, Graeme Saggers, Tracy Johnson, Sander Kramer

Editor(s): Ivan Lazarov & Sam van der Vlugt

Blueprint for Individual Income Taxation Reform in a Globalized World
Chapter 1: Rethinking Residence and Source Tax Rules for Individuals in an Increasingly Globalized and Digitalized World
Chapter 2: A New Nexus Requirement for Individuals in a Globalized World: An Analysis under Personal Income Tax, Labour Law and Social Security Law
Chapter 3: (Some) Coherence in Migrants’ Tax Liability? “Special” Tax Regimes as a Reflection of the Process of Migration
Chapter 4: Unilateral Tax Policy for Attracting High-Skilled Individuals in a Globalized Economy
Chapter 5: Competing for Taxpayers: A Blueprint to Identify and Assess Harmful Tax Regimes for Individuals
Chapter 6: “Certainty” in Individual Tax Residency and the Interpretation of Tiebreaker Rules in Tax Treaties
Chapter 7: Revised Attribution of Taxing Right for Independent Services and Employment Income: Withholding Taxes on Non-Resident Taxpayers
Chapter 8: Does EU Citizenship Justify Taxing Individuals in the European Union?
Chapter 9: Personal Income Tax as an EU Own Resource
Chapter 10: Global Charitable Giving: Removing Tax Obstacles for the Free Movement of Individual Philanthropic Capital
Chapter 11: Double Non-Taxation on Cross-Border Personal Pension Income
Chapter 12: The Role of Negative and Positive Integration in Reconciling Article 18 with Different Pension Taxation Regimes