International taxation and migrations

Abstract

The migration of individuals is one of those phenomena which yearn for the attention of dedicated researches within the ambit of international taxation, as it puts to the test some of its basic foundations. Modern technological advancements, the changes in the way in which human labor is performed, developments in our cultural attitudes to the concepts of family and home, as well as the globalization of our societies seen perhaps most evidently in the dominance of the English language as the first true planetary lingua franca has enabled an unprecedented mobility and interaction of humanity. This Chapter attempts to outline the potential consequences of the described developments on the existing international tax order and focuses on the impact of migratory tendencies on the concept of tax residence (i.e., on what we see as justifying unlimited tax liability), on the effect of migration enabling developments, primarily technological and those related to the way in which work is performed on our understanding of where is the source of income, the growing problem of the brain (and increasingly population) drain, and on the dangers to our social contract which emanate from the measures to attract or keep certain sections of population.