当代,世界各国推行的个人所得税制实施的税收管辖原则不尽相同。除了少数国家(地区)仅实行单一的所得来源地管辖原则以外,大多数国家采取纳税人居住地与所得来源地相结合的原则行使税收管辖权。即对居民从本国境内和境外取得的所得都行使征税权,通常称为属人主义,而对非居民则仅限于对来源于该国的所得进行征税,通常称为属地主义。这样,就有一个居民纳税义务与非居民纳税义务的判定问题。对此,每个国家都详尽规定了自己的判定标准,但无论怎样规定,绝大多数国家都不外乎是从空间和时间两个方面加以判定,即看其是否拥有永久性住所和居住时间的长短。 At present, the tax jurisdictions implemented by the individual income tax system in various countries in the world are not the same. Except for a few jurisdictions where only a single source of income jurisdiction is applied, most countries exercise tax jurisdiction on the principle that the taxpayer’s place of residence is combined with the source of income. That is to say, the exercise of the right of taxation on income derived by inhabitants both within and outside their own country, commonly referred to as egalitarian, while non-residents are limited to the taxation of income derived from that country, commonly termed sedentary. Thus, there is a resident tax liability and non-resident tax liability determination problem. In this regard, each country has exhausted its own determination criteria, but no matter what, most countries are no more than space and time to be judged from two aspects: to see if they have a permanent residence and residence time The length of