La residencia de las personas físicas como nexo de la tributación de la renta en los ordenamientos jurídicos español y británicola especial incidencia del Derecho de la Unión Europea

Abstract

The criterion of residence for tax purposes is now regarded as the most effective connecting factor to tax on individuals. However, the concept of tax resident in the international perspective, in the EU and even within different Member states forming the latter lacks a clear definition and is immersed in numbers due to the ongoing conflict in the power overreach States tax. Therefore, in this study we have investigated both limits the taxing power of the state, the concept of tax residence in the international and the European Union, including disputes arising from Spain and the UK's membership of the European Union and the International Community. After considering this substance, the thesis goes on to explore the limits beyond two different legal systems -Spanish and British- to consider an individual resident for the purposes of Income Tax and Capital Gains.