International - Citizenship and Tax
- G. Beretta
- World Tax Journal, 2019 (Volume 11), No 2
- 2 April 2019
Since the time of the ancient Greeks and Romans, citizenship has defined the membership of an individual to a polity. Despite being a central pillar of national states and a supranational institution like the European Union, the importance of citizenship has progressively declined due to globalization and increased cross-border mobility. Indeed, citizenship has almost been abandoned as a connecting factor for establishing a state’s tax jurisdiction. This article, however, argues that such a perception is partly misplaced. Far from being a relic of the past, citizenship still maintains relevance in today’s international tax arena. Citizenship can serve, at times, either to extend or restrict a state’s taxing rights over an individual’s income. And yet, the use of citizenship for tax purposes is often instrumental and does not reflect the effective participation of an individual in a polity, which might ultimately suggest abandoning citizenship altogether as a relevant connecting factor in jurisdictional tax matters.