Tax aspects of citizenship by investment

This article examines how legal identity – particularly citizenship and residence – shapes international tax enforcement in an era of mobility and investment-based migration. While most tax regimes anchor liability in residence rather than citizenship, schemes that offer Citizenship or Residence by Investment blur the practical line between these categories. We argue that although citizenship is not a determinative factor for tax liability in most jurisdictions, it can significantly affect enforcement outcomes under frameworks such as the Common Reporting Standard. By analysing how CBI and RBI programmes interact with self-certification processes and treaty residence rules, we show that identity-based arbitrage can frustrate information exchange and facilitate tax evasion. This understudied link between legal identity and enforcement calls for renewed scrutiny of commodified citizenship and residence in global tax governance.