Taxation of Foreign-Source Income of Resident Individuals

The 21st century is characterized by unprecedented economic and technological globalization. An increasingly free cross-border flow of goods, services, capital and workforces has led to a greater integration of economies across the world. These developments have also posed some challenges to national tax systems. A seemingly simple rule most countries have adopted and maintained for decades that residents ought to pay taxes on their worldwide income now has to prove its feasibility in the face of these new realities. There is an open question as to how to administer this residence-based tax regime in a world in which states’ administrative capacities are highly restricted to their national borders while their residents increasingly trade, invest and provide services across borders.

This book aims to introduce a new way of exploring an old but increasingly important topic in income taxation: the enforcement of taxes on the foreign-source income of resident individuals. Central to this discussion is the emerging “automatic exchange of information” (AEOI) system. The author explores the emerging AEOI Standard among governments as a potential mechanism to address the issues and attempts to provide much-needed historical research, conceptual clarification and theoretical support of AEOI. The author also analyses the need for a fair international legal framework for AEOI and discusses the particularities and challenges associated with establishing such a framework.