Tax competition is no longer a notion affecting only the taxation of corporations. The proliferation of special tax regimes (hereinafter, 'STRs') in several countries aimed at attracting the tax residence of individuals - whether highly skilled or simply high-net-worth - has shifted traditional discussions about harmful tax competition and the roce to the bottom to the taxation of
natural persons'. This proliferation of STRs, together with growing concerns in public discourse regarding the effective taxation of ultra-high-net-worth individuals has led to a renewed interest in policy proposals aimed at ensuring a minimum level of taxation that extends beyond its traditional target of multinational corporations.
Against this background and despite growing public scrutiny. STRS are widely used policy tools aimed at attracting human capital into a country. Although their aims, eligibility requirements, duration and tax implications vary widely across jurisdictions, STRs generally share a common defining feature: they grant individuals the possibility to acquire tax residence within a country while being subject to a degree of tax liability that is less comprehensive than the general rules applicable to other individuals resident in that jurisdiction ('ordinary residents'), whether in the form of exemptions, reduced rates, alternative methods of determining the tax base, or a combination thereof.
Ver el capítulo completo en: Decem lustra: Essays and Personal reflections in honor of Kees van Raad. International Tax Center (ITC), 26 October 2025.
October 26, 2025
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