The Race for New Residents: Preferential Regimes and Rethinking Tax Residency under the New Phase of Tax Competition

Preferential regimes aimed at attracting new residents have become widely adopted in recent decades. This includes measures offering residence or citizenship in exchange for investments, as well as provisions for digital nomads designed to facilitate the settlement of these highly mobile individuals. The shift to individual-focused tax policies and their proliferation, once marginal, has introduced in the field of personal taxation mechanisms of attraction and tax competition previously associated mostly with corporate taxation, raising two primary issues. First, like any form of harmful tax competition, it may lead to the improper allocation of the tax base and the risk of double non-taxation. Second, it may result in forms of abuse that affect the same states, nullifying the desired benefits of increased revenue and economic development. As a result, the creation of new rules or, at the very least, international standards to address the adverse consequences of such policies requires careful consideration. This includes reevaluating the concept of tax residence in a mobile reality and exploring ways to coordinate national policies to curb the ongoing race to the bottom.