there are still concerns over the distribution of tax revenues and other economic
benefits. Whereas adopting unilateral relief is always preferred to
not alleviating double taxation, doing so leaves tax revenue to the source
country; the residence country’s investors face a considerable tax burden.
Thus the residence country achieves only its second best outcome: itwould
be better off if double taxation were avoided and if it had the right to tax.
Given its willingness to grant double tax relief unilaterally, the residence
country has an incentive to limit the taxation rights of the source country.
A lower source tax would reduce the tax burden of its investors abroad
and, given that it employs the credit or deductionmethod to avoid double
taxation, it can collect the residual taxes on the foreign income without
raising the overall tax burden on international investment. The interests
of the source country are just the opposite: it favours higher source taxes.
Note that all countries are residence and source countries at the same time,
but to different degrees. Consequently, their distributive interests will be
determined by their relative investment positions: net capital importers
have strong source interests, whereas net capital exporters will have residence
interests.Many big countries are net capital exporters, whereas small
countries are often net capital importers. Overall, the structure of the ‘double
tax avoidance game’ is that of a coordination game with a distributive
conflict.3