This book represents the end of an exciting journey that started in early 2022 with the essential idea to add something which many in the international tax community felt was lacking. Namely, since 2013, we have seen unprecedented efforts in transforming the global tax structure. However, these have been exclusively focused on corporate income taxation, primarily of multinationals, while little or no attention was paid to personal income taxation. Individuals who belong to the wealthiest sections of society are increasingly prone to changing their allegiances due to taxation. Economies are focusing on attracting human capital – talent – with increasing vigour. Furthermore, the way in which we as humans work, as well as our everyday lives and habits, have also been deeply impacted by technological developments. The very nature of employment is rapidly changing, with our laptops and tablets becoming our offices and places of work. Today, humans are more mobile than ever in history, while the emergence of the English language as the true planetary lingua franca opens venues for inclusion of individuals in (for them) previously foreign environments, which never in the past existed on such a global scale. When completing a simple tax return, we are increasingly communicating with bots – artificial intelligence – instead of talking to civil servants. Inadvertently, these developments, which are impacting the lives of individuals, are also affecting the ways in which companies are doing or organizing their businesses. As none of the previously mentioned issues have been comprehensively addressed within the international tax academy, this book attempts to fill the void by providing an in-depth analysis of how the mobility of humans permitted by digitalization impacts direct taxation, both corporate – but more importantly individual – income taxation. In other words, its main objective is to designate relevant topics and open up the debate, which will most certainly become of primary relevance in the near future. Actually, developments from the United Nation and the OECD testify to the fact that the future is now.
