This article assesses the impact of residence-based taxation on business income taxation, suggesting its diminishing importance.
This article assesses the role of residence-based taxation in business income taxation. It argues that its significance is diminishing due to the polysemy of corporate residence, increasing electivity of residence and difficulties in accurately taxing individual shareholders’ income. The article outlines three scenarios for a future with a reduced role for residence-based taxation.
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Yoshihiro Masui (2026) studied this question.
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