Taxpayers’ ability to shift profits and losses creates tax competition,
in which small and big countries have divergent interests. Tax havens –
always small countries – are the winners of tax competition. In fact, being
a tax haven implies a country’s willingness to create a tax system geared
towards the needs of foreign taxpayers. Tax havens use tax sovereignty
not to impose taxes on their legitimate share of the transnational tax base,
but rather to ‘poach’ the tax bases of other countries (Palan, 2003). Some
tax havens adopted this status as an economic development strategy. They
are in a position of ‘provocative dependence’ (Hampton and Christensen,
2003); they need the offshore sector for economic survival, but they are
also viewed as ‘renegade states’ (Eden and Kudrle, 2005) by so-called hightax
nations. To compete for the transnational tax base, havens specialize
in different tax planning activities.9 Empirical evidence shows that their
operations are profitable (Hines, 2005).