International single taxation: A misguiding notion

This chapter enshrines some reflections presented during the Oxford-style debate within the IBDF Duets in International Taxation: Single Taxation? (Amsterdam, 5 October 2017). The motion of the House was: “This House believes that the notion of single taxation is a worthless chimera”, and the authors were entrusted with the task of supporting the stance. The discussion concerned the guiding potential of the idea of single taxation in the process of rethinking the current international tax rules, and several interesting considerations emerged during the debate, despite its ludic nature.

This chapter intended to demonstrate how the idea of single taxation has no guiding potential within the process of rebuilding the current international tax framework. First, it was highlighted that the concept of single taxation itself, albeit intuitive prima facie, is actually vague and inconsistent. It does not entail per se any positive implication unless assessed from a supranational perspective. Moreover, the concept ultimately clashes with other less controversial principles of international taxation. After testing the notion of single taxation in the light of those benchmarks, the common result is that the idea that international income should be taxed just once is misguiding, as it is completely oblivious to the more pressing jurisdictional issues. Taking into account all of the arguments illustrated throughout this chapter, the authors are more than convinced that the idea of single taxation indeed turns out to be a “worthless chimera”.