Do states have an entitlement to tax income arising in their territory?

Laurens van Apeldoorn

Research output: Contribution to journalArticleAcademicpeer-review


This article provides a philosophical assessment of what the author will call the “entitlement principle”, according to which states have an exclusive moral right to tax the income arising in their territory. Based on a minimal standard of international justice the author will argue that the application of the principle is conditional upon there being no deficits in the right to subsistence abroad (in so far as such deficits can be prevented by curtailing that entitlement). Given existing deficits in relation to subsistence rights, reform of the international tax regime should seek to constrain the capacity of reasonably affluent states to tax income arising in their territory, in order to increase the capacity of low-income states to mobilise revenue for poverty alleviation and sustainable development.

Original languageEnglish
Pages (from-to)557-567
Number of pages11
JournalBritish Tax Review
Issue number4
Publication statusPublished - 2019
Externally publishedYes


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