3.1.1.1 Variety of concepts determining the personal nexus between a person and a state

As mentioned in chapter 2 of this study, the jurisdictional scope of inheritance and gift taxes – two representative examples of death taxes and taxes on gifts, respectively – is mainly determined by a personal nexus rule, which, if satisfied, results in a worldwide tax liability. Countries assess this nexus either at the level of the deceased or the beneficiaries or even at both levels of the deceased and the beneficiaries based on one or more concepts. The most representative personal nexus concepts are residence, domicile and nationality. However, the diverging interpretation of these concepts and the application of different concepts to a cross-border inheritance and donation may often give rise to double or multiple taxation of the mortis causa or inter vivos transferred property.