
doi: 10.2139/ssrn.4521472
handle: 21.11116/0000-000F-4C38-E
More and more countries offer tax benefits to attract wealthy individuals and sought-after experts.Under these regimes, mobile individuals are not subject to worldwide taxation on income and wealth any more. As many source countries waive their territorial taxing rights in order to attract investment and economic activities, the ensuing interaction between home countries (not willing to apply worldwide taxation) and source countries (not willing to apply territorial taxation) can result in double nontaxation.Against this background, this article asks whether “everybody is obliged to pay taxes somewhere”.This issue is examined under three different perspectives:- the “legal” perspective which shows how tax competition is undermining “full taxation” ofindividuals;- the “factual” perspective which clarifies to what extent the passing-on of indirect taxes andthe phenomenon of “tax incidence” provide for a factual tax burden on those individualswhich are formally tax exempt.- The “moral” perspective which looks to states and individuals as moral agents. This part triesto disentangle the moral responsibilities of states and individuals when it comes to payingthe “fair share”. It is found that - as long as there is no global tax organisation providingglobal public goods or global redistribution and as long as no state (neither the state of originnor the state of destination) have a clear prerogative and obligation to tax those individuals –individuals are not morally obliged to submit to meaningful taxation in “some” state.
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