The Role of Residence-Based Taxation in Business Income Taxation

New
Journal
Author
Masui, Y.
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2026 (Volume 80), No. 4/5
FormatPDF
EUR
45
| USD
50 (VAT excl.)

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.