Source-vs. Residence-based Taxation in the European Union: The Wrong Question?

Abstract

Abstract Observations such as these raise questions about the usefulness of the traditional ‘source’ and ‘residence’ principles as devices to define the frame¬ work of neutrality and equity choices. Indeed, are these principles alternatives, or do they rather establish limits of a continuum on which the optimal position is in increasing doubt, owing to contemporary economic developments? We suggest in this chapter that ‘source’ and ‘residence’ are best understood as proxies for a practical paradigm to allocate world-wide income (and tax base] in line with underlying economic income and that we may need a new paradigm to achieve this goal more adequately in the world of today and, even more, that of tomorrow.

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