The Role of Residence-Based Taxation in Business Income Taxation
New
Journal
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2026 (Volume 80), No. 4/5
Document
This article assesses the role of residence-based taxation in business income taxation. It argues that its significance is diminishing due to the polysemy of corporate residence, increasing electivity of residence and difficulties in accurately taxing individual shareholders’ income. The article outlines three scenarios for a future with a reduced role for residence-based taxation.