Taxing People, Not Residents

52 Pages Posted: 11 Mar 2024

See all articles by Yariv Brauner

Yariv Brauner

University of Florida Levin College of Law

Date Written: February 13, 2024


Essentially all states tax their residents’ worldwide income. This norm is difficult to justify beyond vague notions of state provided benefits enjoyed by residents. Recent increased mobility (particularly tax-motivated mobility of wealthy individuals) and the growing importance of remote work and digital nomadism present a serious challenge to this linking of residence and taxing rights. This article examines whether exclusive source taxation of individuals could replace the existing rules which are based on a compromise between residence and source taxation. The article concludes that exclusive source taxation of individuals is both feasible and desirable, mainly due to its fairness and legitimacy traits. It further explores the conditions under which such reform could be successfully implemented with the aim of preserving the stability of the existing international tax regime.

Keywords: tax, international tax, remote work , labor mobility, digital nomads

JEL Classification: K33, K34

Suggested Citation

Brauner, Yariv, Taxing People, Not Residents (February 13, 2024). Available at SSRN: or

Yariv Brauner (Contact Author)

University of Florida Levin College of Law ( email )

P.O. Box 117625
Gainesville, FL 32611-7625
United States
3522730949 (Phone)

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