In lieu of original content, here is an excerpt from Angelo Nikolakakis’ “Civil Law and Common Law Perspectives: A View from the Left”, in Guglielmo Maisto, Residence of individuals under tax treaties and European Community law (IBFD, 2010). Beginning at page 81 (footnotes omitted):
Generally, non-residents are either not entitled or not in a practical position to enjoy the same public benefits as residents. Why then should they bear similar — or more onerous — income tax burdens as residents (all the while focusing the question on domestic sources), putting aside source-country opportunism? Continue reading
