A Viable International Tax-Order for Cross-Border Pensions

There is strong evidence that the existing pattern of cross-border pension taxation in OECD countries and beyond is extremely diverse and inconsistent and thus generates a double equity dilemma for individuals and countries alike. We argue that this dilemma cannot be solved within the current double-taxation treaty network and therefore propose a new conceptual framework for the taxation of old-age pensions in a world of high and increasing cross-border mobility of workers and pensioners. We demonstrate that a coordinated move to a front-loaded pension tax system and exclusive source taxation would pave the way for an international pension tax order which eliminates the double equity dilemma. As an additional innovative element of front-loaded pension taxation we discuss the decoupling of individual tax assessment and tax payment which may prove helpful by smoothing transitional effects when the front-loaded pension tax system is introduced.