Nexus Requirements for Taxation of Non- Residents’ Business Income: A Normative Evaluation in the Context of the Global Economy

This book explores one of the most fundamental issues of international tax law: the conditions under which a state may assert a taxing claim over business income derived by a person who is neither its national nor its resident. The term “nexus” or “genuine link” is commonly used in international tax scholarship to describe such basic requirements for the exercise of income tax jurisdiction. When it comes to non- residents, income tax is intimately connected to the notion of “source”, in that every state has the right to tax income derived from sources located within its territory. The main purpose is to analyse the appropriateness of different nexus norms used by states in the taxation of non-resident business income. Particular attention is drawn to developments associated with the global economy, e.g. the introduction and expansion of e-commerce and the rise in cross-border services trade. Methodologically, the value- oriented approach is followed, analysing the research question in light of traditional tax policy benchmarks, such as equity, neutrality and administrability