The Impact of an Abrupt Change Caused by COVID-19 on the Taxation of Expatriates in Residence-Based Tax Systems

Many businesses now operate worldwide because of globalization. As a result, human capital is shifting from one tax jurisdiction to another. Understanding the tax rules of different countries is necessary for this movement of human capital. There are some things countries have in common, such as taxing residents on their worldwide income, and the tax exemption on income from a foreign employment. It is possible to compare the tax systems of countries that use residence-based taxation, such as Australia, Ghana, South Africa, and the UK. In 2020, the world experienced COVID-19. Governments were driven to put into effect temporary measures such as restricting both international and domestic travel. Therefore, many expats were forced to remain in their host or home countries. The objective of this research was to explore whether the procedures and measures put in place by the tax authorities adhered to the fairness principles (distributive and procedural) which is the theoretical framework of this study and how the abrupt changes brought by COVID-19 affected the income taxation of expatriates. Prior studies only focused on the changes in the expatriate taxation and not on the elements of fairness when changes are implemented. This is the gap this study will fill. Through the qualitative research methodology, primary and secondary data were used. The study compared different countries using the comparative methodology. The conclusions demonstrate that the procedures and the amendments made are fairer and practical for the countries who implemented them. Future studies may consider the inclusion of more developing countries to conduct quantitative comparative research to evaluate principles of fairness during abrupt changes in the tax laws.