Relieving Double Taxation on Cross-Border Services: A Comparative Analysis of Major Exporting Countries
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Bulletin for International Taxation Volume 80, No. 8
This article compares how 12 major exporting countries relieve double taxation on remotely delivered cross-border services. It finds that such income is generally not treated as foreign-source, limiting unilateral foreign tax credit relief. Where credits apply, differing calculation rules create unequal outcomes across exporters, especially for low-margin or loss-making providers.
Frederik Heitmüller is an Associate Postdoctoral Fellow with ICTD’s International Tax Team. His research focuses on policies against corporate tax avoidance, the influence of international norms in the Global South and global tax governance. He is also an independent consultant on tax policy.
Prior to joining ICTD, he obtained a PhD from Leiden University, Netherlands, where he investigated the political economy of the BEPS Project in the Global South as member of the GLOBTAXGOV project, and taught courses on international and comparative taxation. He has a master’s degree in political science from Sciences Po Bordeaux and University of Stuttgart.
Florian Dierich is a consultant currently working as an Associate Research Officer with the International Tax Team at ICTD. His work focuses on international tax cooperation. Previously, Florian has worked on international tax frameworks, including the OECD’s Two-Pillar Solution, the Global Solidarity Levies Task Force and EU tax policies. He holds a Research Master’s in Political Science from Sciences Po Paris.
Yvette Nakibuule Wakabi is the Principal Associate for Africa and the Middle East, and the Programme Manager for the Centre for Studies in African Taxation at the IBFD.
