In the political debates, these normative issues mingledwith distributive
conflicts between capital importers and exporters – the former favouring
the source principle and the latter the residence principle – since the respective
solution would give each a bigger share of the international tax
base (see e.g. Dagan, 2000). To make a long story short, the solution that
emerged represents a compromise between both principles on a case-bycase
basis. Broadly speaking the primary (or exclusive) right to tax active business income is granted to the source country; the residence country,
by contrast, has the primary (or exclusive) right to tax passive income, i.e.
interest, dividends or royalties (see e.g. Avi-Yonah, 2006).