Abstract: The Government of the Unitary State of the Republic of Indonesia has a significant and long-term goal, namely that by 2045 it can get out of the middle-class income trap. Indonesia is a constitutional state based on Pancasila and the 1945 Constitution of the Republic of Indonesia to create the peoples welfare and prosperity. This prosperity goal can achieve through fair and equitable tax collection. Tax collection is imposed on all citizens in Indonesia, including foreign nationals. In determining the tax subject, Indonesia does not look at citizenship to make it possible for foreign citizens to become domestic tax subjects. Domestic tax subjects status for foreign citizens will have an impact on taxation with the concept of worldwide income to the income they have.