A two country model of growth is developed in which cross country diff
erences in growth may arise from differing internal rates of taxation
on the earnings of physical capital under a residence based tax rule.
Under the source rule, after-tax rates of return and rates of growth o
f income and consumption are equal world-wide. The spillover effects o
f foreign taxation on the domestic growth rate and the competitive eff
ects of tax policy are also examined. Both of these, in part, depend u
pon the tax rule which is in use.