Yoram Keinan (Michigan) has published The Case For Residency-Based Taxation of Financial Transactions in Developing Countries, 9 Fla. Tax Rev. 1 (2008).  Here is part of the Introduction:

The question addressed by this article is whether a developing country (hereinafter “Country D”) is better off adopting a source-based or residency-based taxation regime (or a combination thereof) for cross-border financial transactions. Financial transactions add an important dimension to the general conflict between source-based and residency-based regimes since money is fungible. hus, when a non-resident wishes to invest overseas, the investor can easily switch from one country to another, and will do so if the tax rules in Country D could result in a heavier tax burden.

Nevertheless, for developing countries, choosing between source-based and residency-based taxation is not easy. On the one hand, a source-based regime would allow Country D to keep more tax revenues from non-residents. Assuming that Country D has source rules similar to most other countries with respect to financial transactions, a source-based regime would allow Country D to tax income derived by non-residents from interest and dividends paid by domestic entities. On the other hand, non-residents from countries that have a residency-based taxation regime would be less inclined to invest in Country D, since their home country would impose tax on such non-residents' activity in Country D. This might result in double taxation if no treaty applies, and there is no other relief from double taxation.  Furthermore, as set forth below, residency-based taxation promotes Capital Export Neutrality. As this article concludes, the adoption of a residency-based taxation regime for financial transactions by developing countries would benefit Country D in terms of attracting foreign investment.