The Utility of Tax Residence Tests beyond Taxing Rights and the Concept of “Tests of Belonging” Given the Growing Number of Multilateral Provisions in the Context of Territorial Tax Regimes with Special Reference to Gibraltar and Hong Kong

This article discusses tax residence and its utility beyond a demarcation of taxing rights. Taking Gibraltar and Hong Kong as examples, it argues that the act of claiming tax residence is an act of sovereignty, and predicates participation in the international tax community for territories.