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Progressive taxation has historically been discussed primarily in the context of developed, Western nations. This Article considers its application in two developing, nonwestern economies, emphasizing the differences in political, economic, and (especially) cultural contexts and their effect on the progressivity equation. In India these differences include long-standing attitudes, such as the Hindu tradition’s historic ambivalence towards utilitarian arguments, and shorter-term institutional arrangements, such as the division of power within India’s federal system and the tax exemption for agricultural income. In China they include the legacy of Marxism as well as a more long-standing tendency to resolve legal and policy issues based on notions of communal rather than individual welfare. Both countries have limited administrative resources and (by Western standards) a relatively small middle class, so that the income tax remains a relatively small albeit growing source of national revenues. In this Article I consider the impact of these factors, and conclude by asking whether a similar "tax life cycle" will apply to both countries or political and cultural differences will result in divergent tax patterns. Furthermore I also evaluate the progressivity problem as a case study in comparative taxation and assess the need to develop a more sophisticated methodology for dealing with institutional, attitudinal, and other cultural differences.

From Mumbai to Shanghai, with a Side Trip to Washington: China, India, and the Future of Progressive Taxation in an Asian-Led World