At the beginning of the first stage, international investment is subject
to double taxation because all countries exert their right to tax to the full.
Double taxation results from an overlap of jurisdiction to tax between
a residence state, where a recipient of income lives, and a source state,
where that recipient’s income was generated. Double taxation hampers
trans-border economic activities; domestic investment is favoured over
international investment (e.g. Musgrave, 2006). Since there are collective
gains to be made from liberalizing, big and small country governments
alike, in their capacity as residence countries, have a collective interest in
avoiding double taxation. Further, it can be shown that governments also have an individual interest in providing double tax relief, irrespective of
whether other governments do so. Double tax relief is a coordination game.
Empirically this is evidenced by the fact that all governments provide
unilateral tax relief on foreign source income.