Out of all double tax treaties (DTTs) in force in 2012, around 41% are symmetric and 59% are asymmetric, i.e., they prescribe different dividend withholding tax rates (WTRs) depending on the foreign investor's ownership fraction. The paper investigates the reasons for this phenomenon, namely why...

This study investigates the impact of residence country’s double tax relief method and of tax sparing agreements, on the difference between developing countries’ withholding taxes under domestic law, and negotiated withholding taxes in tax treaties with OECD member states. Using a dyadic...