PIL.OT / DEVELOPMENT
Tax aspects of citizenship by investment
Development summary
Allison Christians and Werner Haslehner analyse how citizenship-by-investment (CBI) and residence-by-investment (RBI) schemes shape international tax enforcement in an era of increased mobility. They argue that, although tax liability in most systems is tied to residence rather than citizenship, these schemes’ interaction with self-certification processes and treaty-residence rules can affect enforcement under the Common Reporting Standard.