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This paper presents a critical analysis of the origin of majority and minority carrier substrate currents in tunneling MOS capacitors. For this purpose, a novel, physically-based model, which is comprehensive in terms of impact ionization and hot carrier photon emission and re-absorption in the substrate, is presented. The model provides a better quantitative understanding of the relative importance of different physical mechanisms on the origin of substrate currents in tunneling MOS capacitors featuring different oxide thickness. The results indicate that for thick oxides, the majority carrier substrate current is dominated by anode, hole injection, while the minority carrier current is consistent with a photon emission-absorption mechanism, at least in the range of oxide voltage and oxide thickness covered by the considered experiments. These two currents appear to be strictly correlated because of the relatively flat ratio between impact ionization and photon emission scattering rates and because of the weak dependence of hole transmission probability on oxide thickness and gate bias. Simulations also suggest that, for thinner oxides and smaller oxide voltage drop, the photon emission mechanism might become dominant in the generation of substrate holes.