Tax sparing should not be treated as a foreign aid tool, but that instead, it should be used as an effective treaty device where both residence states and source states may benefit from in order to achieve ‘two-headed’ goals. As tax sparing changes the present zero-sum game for sharing tax revenue from involving two-parties to involving three-parties, doubts and criticisms will unavoidably arise. However, the successful approaches of Singapore, as well as China’s resumed use of this mechanism, demonstrates that tax sparing may be effective if, and when, used well.
Intertax