Abstract
Citizenship and taxation are closely related. While only two countries tax on the basis of citizenship, residency as it is implicated in abode and domicile, determines taxation obligations, criteria, and rates. Countries tax on the basis of residency, applying a 183- day presence rule together with other tests that cluster around definitions of ‘the home’ to establish abode and/or domicile which are invoked to classify taxpayers and their payments. Since 1984, a number of countries have been offering Citizenship by Investment (CBI) and Residence by Investment (RBI) programmes as incentives to encourage High Net Worth Individuals (HNWIs) to migrate and settle within their jurisdictions. Competition for CBI and RBI has intensified since the turn of the twenty-first century. These programmes allow both states and their HNWI clients to negotiate abode, domicile, and home to reduce tax obligations. While anthropologists have long since abandoned assumptions that fix culture to specific places, tax authorities struggle to accommodate the mobile livelihoods that are instantiated in CBI and RBI programmes. While the majority of citizens continue to pay tax in place, HNWIs, with multiple homes in multiple places, treat citizenship as a commodity to reduce, and even entirely escape taxation.