ABSTRACTThe gain to competing governments from entering into binding non-preferential tax agreements (that prevents discriminatory taxation in favor of mobile capital) depends on the extent of capital mobility between jurisdictions. In particular the gain is increasing in the cost of relocation of capital and the fraction of the domestic tax base which is relatively immobile. We show this in a symmetric model of tax competition between two governments where all capital is imperfectly mobile and differ only in their cost of relocation.