Stepping Back from the Edge: Australia Retreats from Proposed Domestic Law Changes that Sought to Override Its Tax Treaties

New
Journal
Author
Dirkis, M.J.
Country
Australia; International; OECD
Published Date
Issue
Bulletin for International Taxation 2026 (Volume 80), No. 9/10
FormatPDF
EUR
45
| USD
50 (VAT excl.)

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.