Relieving Double Taxation on Cross-Border Services: A Comparative Analysis of Major Exporting Countries

Free Journal - Open Access
Journal
Author
Heitmüller, F.; Isa, A.A.; Dierich, F.; Nakibuule Wakabi, Y.
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2026 (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.