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Exemption vs. Credit Method in International Double Taxation Treaties

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  • Thomas Dickescheid

Abstract

This paper examines the choice of international double taxation relief methods by two small countries that mutually exchange foreign direct investment. At the first stage, each country chooses between the exemption and the credit method (as prescribed by the OECD model treaty) and at the second stage, each country sets nationally optimal non-discriminatory capital tax rates. It is shown that in the subgame perfect equilibrium both countries choose the exemption method. Mutual application of the exemption method is also shown to yield the highest welfare for each country. While the tax export effect generally induces both countries to choose inefficiently high tax rates, this effect is weakest when both countries exempt foreign earned profits from domestic taxation.

Suggested Citation

  • Thomas Dickescheid, 2004. "Exemption vs. Credit Method in International Double Taxation Treaties," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 11(6), pages 721-739, November.
    • Handle: RePEc:kap:itaxpf:v:11:y:2004:i:6:p:721-739
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    Cited by:

    1. Hristu-Varsakelis, Dimitrios & Karagianni, Stella & Saraidaris, Anastasios, 2011. "Equilibrium conditions in corporate tax competition and Foreign Direct Investment flows," Economic Modelling, Elsevier, vol. 28(1-2), pages 13-21, January.
    2. Harendt, Christoph & Dreßler, Daniel & Overesch, Michael, 2016. "The Impact of Tax Treaties and Repatriation Taxes on FDI Revisited," VfS Annual Conference 2016 (Augsburg): Demographic Change 145588, Verein für Socialpolitik / German Economic Association.
    3. Adriana CAZACU, 2020. "International Double Taxation. Content, Consequences and Avoidance (I)," CECCAR Business Review, Body of Expert and Licensed Accountants of Romania (CECCAR), vol. 1(8), pages 62-72, August.
    4. Dreßler, Daniel, 2012. "Form follows function? Evidence on tax savings by multinational holding structures," ZEW Discussion Papers 12-057, ZEW - Leibniz Centre for European Economic Research.
    5. Siggelkow, Benjamin Florian, 2013. "Tax Competition and Double Tax Treaties with Mergers and Acquisitions," MPRA Paper 49371, University Library of Munich, Germany.
    6. Adriana CAZACU, 2020. "International Double Taxation. Content, Consequences and Avoidance (II)," CECCAR Business Review, Body of Expert and Licensed Accountants of Romania (CECCAR), vol. 1(9), pages 61-72, September.
    7. Kudła, Janusz & Kopczewska, Katarzyna & Stachowiak-Kudła, Monika, 2023. "Trade, investment and size inequalities between countries and the asymmetry in double taxation agreements," Economic Modelling, Elsevier, vol. 122(C).
    8. Hristu-Varsakelis, Dimitrios & Karagianni, Stella & Saraidaris, Anastasios, 2011. "Equilibrium conditions in corporate tax competition and Foreign Direct Investment flows," Economic Modelling, Elsevier, vol. 28(1), pages 13-21.

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