Yariv Brauner (Florida; Google Scholar) presents You Play, You Pay! Mobility, Territory and Exclusive Source Taxation in the 21st Century at the Institute of Austrian and International Tax Law today as part of its Colloquium on Current Developments in European and International Tax Law: 

The demise of residence as an appropriate basis for taxation in the 21st century requires a rethinking of the international tax regime. This article continues the exploration of (both individual and corporate tax) reform based on exclusive source taxation. Demonstrating that such reform is possible and desirable for the survival of the international tax regime is the primary contribution of this article. The other main contributions are an explanation of the benefits of a single rather than dual basis for income taxation, and a detailed analysis of the existing source rules and their potential reforms. The latter have come under criticism as ineffective and incompatible for the realities of the 21st century. The article explains that the critique of the content of the existing source rules should not automatically count against the principle of source taxation.

It argues that the existing source rules must and can be reformed, regardless of one’s view on the demise of residence-based taxation, demonstrating that such reform could be compatible with the purposes and legitimacy of the wider (exclusive source-based taxation) reform explored herein.

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