under-taxation – comprising the related phenomena of tax competition,
tax evasion and tax avoidance – became a pressing issue. As I show below,
under-taxation is an unintended consequence of the particular institutional
design of double tax avoidance (DTA). Under-taxation has made it difficult
for governments to maintain an efficient and equitable tax system. Despite
these detrimental consequences, the basic approach to avoiding double
taxation and the core principles of the regime have remained unchanged.
Instead of eliminating the root causes of the regime’s weakness, actors only
mitigated some forms of under-taxation through indirect and incremental
institutional reform. How can we explain the institutional persistence of
the tax regime despite its shortcomings?