Stepping Back from the Edge: Australia Retreats from Proposed Domestic Law Changes that Sought to Override Its Tax Treaties
New
Journal
Country
Australia; International; OECD
Published Date
Issue
Bulletin for International Taxation 2026 (Volume 80), No. 9/10
Document
This article examines whether two recent Australian legislative measures amount to tax treaty override: the 2024 amendment limiting the domestic effect of non-discrimination articles and the 2026 proposal to broaden foreign resident CGT rules. It argues that, while override has occurred, it is not a consistent feature of Australian treaty policy.