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The OECD Model Tax Treaty: Tax Competition and Two-Way Capital

Author

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  • Ronald B. Davies

    (University of Oregon Economics Department)

Abstract

Model tax treaties do not require tax rate coordination, but do call for either credits or exemptions when calculating a multinational’s domestic taxes. This contradicts recent models with a single capital exporter where deductions are most efficient. I incorporate the fact that many nations import and export capital. With symmetric countries, credits by both is the only treaty equilibrium, resulting in Pareto optimal effective tax rates which weakly dominate the non-treaty equilibrium rates. With asymmetric countries, the treaty need not offer improvements without tax harmonization. With harmonization, it is always possible to reach efficient capital allocations while increasing both countries’ welfares only if neither uses deductions.

Suggested Citation

  • Ronald B. Davies, 1999. "The OECD Model Tax Treaty: Tax Competition and Two-Way Capital," University of Oregon Economics Department Working Papers 2002-7, University of Oregon Economics Department, revised 01 Jan 2002.
    • Handle: RePEc:ore:uoecwp:2002-7
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    File URL: http://economics.uoregon.edu/papers/UO-2002-7_Davies_Two_Way_Capital_Flows.pdf
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    Cited by:

    1. Dickescheid, Thomas, 2002. "Steuerwettbewerb und Direktinvestitionen," Beiträge zur Finanzwissenschaft, Mohr Siebeck, Tübingen, edition 1, volume 16, number urn:isbn:9783161477348, December.
    2. Thomas A. Gresik, 2001. "The Taxing Task of Taxing Transnationals," Journal of Economic Literature, American Economic Association, vol. 39(3), pages 800-838, September.

    More about this item

    JEL classification:

    • F20 - International Economics - - International Factor Movements and International Business - - - General
    • H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods

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