It is true that governments want to preserve tax sovereignty. The DTA
regime was constructed in a sovereignty-preserving way, so that double
taxation can be avoided by interface regulation. Governments cherish the
flexibility of this setup, which allows them to design their domestic tax
laws independently of other countries. Nevertheless, as an explanation of
institutional design and development, the desire to preserve sovereignty is
incomplete. This becomes apparent when comparing reactions to double
taxation on the one hand to reactions to under-taxation on the other.While
governments preserve their tax sovereignty in avoiding double taxation,
they are nevertheless willing – albeit grudgingly – to relinquish at least
part of their formal sovereignty in the fight against tax evasion and avoidance.
They agree to sharing tax information and increasing administrative
cooperation. In linewithmy explanation, the extent to which governments
manage to actually preserve their sovereignty depends on the functional
requirements of the respective problem. While a sovereignty-preserving
solution is viable in the coordination game of double tax avoidance, the
asymmetric PD of under-taxation requires a sharing of tax sovereignty, in
order for governments to achieve their policy goals.14 This shows that the
concern over sovereignty is not the immovable mover of international tax
governance (Rixen, 2008: 191–93).