Rethinking Residence and Source Tax Rules for Individuals in an Increasingly Globalised and Digitalised World

Event Description

During the past decade, governments around the world have devoted enormous effort to the reform of domestic and tax treaty rules for taxing cross-border income of multinational enterprises (MNEs) in order to respond to tax challenges arising from economic globalisation and digitalisation. In contrast, the implications of increased globalisation and digitalization for individual income taxation has been largely ignored. Because developed countries rely more heavily on individual income taxes than corporate income taxes as a source of revenue, the impact of globalisation and digitalisation on the taxation of individual income may be more consequential than their effects on the taxation of MNEs.

This article aims to contribute to a growing academic literature on the impact of globalisation and digitalisation on individual income taxation, considering challenges to the individual income tax resulting from increased globalisation and digitalisation, and possible responses to these challenges. Part 2 provides context for the analysis, reviewing developments that have increased the mobility of individuals and work in recent years. Part 3 explains key challenges that this increased mobility poses for the individual income tax. Part 4 considers potential responses to these challenges, including unilateral reforms to domestic tax rules, revisions to the OECD Commentary, amendments to bilateral tax treaties, and multilateral initiatives. Part 5 concludes with a plea to broaden the conversation about challenges to the individual income tax and possible responses.

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Speaker

David Duff is Professor of Law and Director of the Tax LLM program at the Peter A. Allard School of Law at the University of British Columbia, where he teaches and writes in the areas of areas of tax law and policy, corporate and international taxation, environmental taxation and distributive justice. 

Prior to joining UBC Law in 2009, Professor Duff was a faculty member of the University of Toronto Faculty of Law. Before that, he was a tax associate at the Toronto office of Stikeman, Elliott. He was also employed as a researcher with the Ontario Fair Tax Commission from 1991 to 1993 and as a tax policy analyst with the Ontario Ministry of Finance from 1993 to 1994.