The Single Tax Principle

4 Pages Posted: 1 Jun 2022 Last revised: 28 Jul 2022

Date Written: May 27, 2022


The single tax principle (STP) is a theory of international taxation developed in the 1990s but
with roots going back to the beginning of the international tax regime in the 1920s. The STP
states that cross border income should be subject to full taxation - neither double taxation nor
double non taxation. Full taxation is defined as the applicable national income tax rate for
individuals and the average corporate tax rate of the major economies (about 25%) for
corporations. This definition, in turn, derives from the Benefits Principle (BP) which states that
individuals should be taxed primarily at their place of residence and corporations primarily at
the source of business profits. The STP requires that if the primary taxing jurisdiction under the
BP does not impose a sufficient level of tax to achieve full taxation, the other jurisdiction
(source for individuals and residence for corporations) should apply additional taxes to ensure
full taxation.

Keywords: Single Tax Principle, Benefits Principle, International Tax Regime

JEL Classification: H26

Suggested Citation

Avi-Yonah, Reuven S., The Single Tax Principle (May 27, 2022). U of Michigan Public Law Research Paper No. 22-024, Available at SSRN: or

Reuven S. Avi-Yonah (Contact Author)

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

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