First, there is self-enforcement deriving from the fact that DTA is a coordination
game. Actors do not want to endanger the coordinating function
of the established regime principles, so they act cautiously in their attempts
to reform. Rule stretching in the area of CFC legislation and transfer pricing
are telling illustrations for this, as is the strategy of layering the project on
harmful tax practices on top of the existing DTA regime. In effect the selfenforcing
process means that the DTA regime not only contributes to the
constitution of tax competition, but it also pre-structures the institutional
reactions to tax competition.