National and International Distributive Justice in Bilateral Tax Treaties

Alexander Cappelen

FinanzArchiv: Public Finance Analysis, 1999, vol. 56, issue 3/4, 424-

Abstract: This paper analyses the choice between the residence principle and the source principle in international capital taxation. The focus of the literature has been on the efficiency aspects of the two principles. The present paper ties in with this literature, but incorporates effects on both national and international equity. It is shown that the choice between the two principles of international taxation to some extent is a choice between national and international inequality. The paper argues that from the perspective of a global planner there might be situations where the source principle is superior to the residence principle because the source principle reduces international inequality.

Date: 1999
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