Powerful governments and societal interests also behave in accordance
with theoretical expectations. TheUS, as the hegemonic power,was central
in setting the standard by being the first country to grant a foreign tax
credit. The importance of powerful actors is further evidenced by the fact
that theOECD – the ‘rich countries’ club’ – became the standard setter. The
UN, which devotes fewer resources and expertise to issues of international
taxation, has not been able to maintain its leading position. While the UN
also produces an MC for bilateral DTTs (United Nations, 2001), its MC
generally reproduces all the basic provisions of the OECD MC.8 Capital
interests, as predicted, favour the avoidance of double taxation; this is
evidenced by the fact that the International Chamber of Commerce put the
issue on the agenda in the first place. Also, as predicted, there has been no
opposition from labour to these developments.