Mobility of Individuals and Workforces
  This book provides an in-depth analysis of how the mobility of humans permitted by digitalization impacts direct taxation, both corporate – but more importantly individual – income taxation.
Why this book?
This book represents the end of an exciting journey that started in early 2022 with the essential idea to add something which many in the international tax community felt was lacking. Namely, since 2013, we have seen unprecedented efforts in transforming the global tax structure. However, these have been exclusively focused on corporate income taxation, primarily of multinationals, while little or no attention was paid to personal income taxation. Individuals who belong to the wealthiest sections of society are increasingly prone to changing their allegiances due to taxation. Economies are focusing on attracting human capital – talent – with increasing vigour.
Furthermore, the way in which we as humans work, as well as our everyday lives and habits, have also been deeply impacted by technological developments. The very nature of employment is rapidly changing, with our laptops and tablets becoming our offices and places of work. Today, humans are more mobile than ever in history, while the emergence of the English language as the true planetary lingua franca opens venues for inclusion of individuals in (for them) previously foreign environments, which never in the past existed on such a global scale. When completing a simple tax return, we are increasingly communicating with bots – artificial intelligence – instead of talking to civil servants. Inadvertently, these developments, which are impacting the lives of individuals, are also affecting the ways in which companies are doing or organizing their businesses.
As none of the previously mentioned issues have been comprehensively addressed within the international tax academy, this book attempts to fill the void by providing an in-depth analysis of how the mobility of humans permitted by digitalization impacts direct taxation, both corporate – but more importantly individual – income taxation. In other words, its main objective is to designate relevant topics and open up the debate, which will most certainly become of primary relevance in the near future. Actually, developments from the United Nation and the OECD testify to the fact that the future is now.
Mobility of Individuals and Workforces
    DOI: https://doi.org/10.59403/2j0zh11
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Chapter 1: Mobility of Individuals, the “Brain Drain” and Taxation in the Digital Age
    DOI: https://doi.org/10.59403/2j0zh11001
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Chapter 2: Global Tax Policy Options for Taxing Billionaires
    DOI: https://doi.org/10.59403/2j0zh11002
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Chapter 3: Tax Residence of Individuals in the Age of Geographical Diversification
    DOI: https://doi.org/10.59403/2j0zh11003
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Chapter 4: A Common Autonomous International Tax Understanding of Employment and Its Potential Relevance for the Future Reform of the Taxation of Employment Income Under Tax Treaties
    DOI: https://doi.org/10.59403/2j0zh11004
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Chapter 5: Social Security in the Age of Digitalization and Mobility: Adapt or Perish?
    DOI: https://doi.org/10.59403/2j0zh11005
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Chapter 6: What Are the Latest Special Tax Regimes that Boost the Relocation of Senior Executives/High-Net-Worth Individuals?
    DOI: https://doi.org/10.59403/2j0zh11006
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Chapter 7: Special Tax Regimes to Attract Individuals and Their Interaction with Treaty Law: Entitlement Issues
    DOI: https://doi.org/10.59403/2j0zh11007
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Chapter 8: Cross-Border Mobility of Individuals and Anti-Avoidance Tax Rules
    DOI: https://doi.org/10.59403/2j0zh11008
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Chapter 9: Taxation of Entertainers and E-sportspersons under Article 17 of the OECD Model in the Digital Era
    DOI: https://doi.org/10.59403/2j0zh11009
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Chapter 10: Taxing the Income of Influencers
    DOI: https://doi.org/10.59403/2j0zh11010
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Chapter 11: A Reflection on the Future of Corporate Tax Residency in the Age of Remote Work and Mobility of Individuals
    DOI: https://doi.org/10.59403/2j0zh11011
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Chapter 12: Rethinking the Allocation of the Rights to Tax Business Income in the Digital Age: Remote Work as a Further Challenge to the Permanent Establishment Concept?
    DOI: https://doi.org/10.59403/2j0zh11012
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Chapter 13: Mobility of Workers and Remote Work after the COVID-19 Pandemic: Is There Still the Need to Stay at Arm’s Length?
    DOI: https://doi.org/10.59403/2j0zh11013
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Chapter 14: The Incidence of Cross-Border Mobility of Individuals on Post-BEPS Substance Requirements
    DOI: https://doi.org/10.59403/2j0zh11014
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Chapter 15: Are the Substance Requirements under the EU Shell Companies Directive Proportional? A Critical Assessment
    DOI: https://doi.org/10.59403/2j0zh11015
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Chapter 16: Mobility, Its Impact on the Existing Profit Allocation System and Spillover Effects on the Pillar Two and Pillar One (Amount A) Systems
    DOI: https://doi.org/10.59403/2j0zh11016
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Chapter 17: Taxing the Acquisition, Ownership and Transfer of Cryptocurrencies and NFTs (Digital Assets) by Individuals
    DOI: https://doi.org/10.59403/2j0zh11017
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Chapter 18: The Evolution of Administrative Cooperation in Tax Matters and the Challenges Raised by Crypto-Assets: Balancing the Need for Effective Enforcement Jurisdiction with the Safeguard of Fundamental Rights in Light of Recent and Prospective Developments within and without the EU
    DOI: https://doi.org/10.59403/2j0zh11018
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Chapter 19: The Taxation of Robots and Its Global Challenges
    DOI: https://doi.org/10.59403/2j0zh11019
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Svetislav V. Kostić, Andrés Báez Moreno, Vikram Chand and Mario Tenore
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