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

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.

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Publication Details

Journal
Bulletin for international taxation
Published
2026-08-27
DOI
https://doi.org/10.59403/254j2vj
Primary Topic
Taxation and Legal Issues
Type
article
Field-Weighted Citation Impact
0.00
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article

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

Michael Dirkis
Bulletin for international taxation
Taxation and Legal Issues
article

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

Michael Dirkis
article en

Abstract

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.

Bulletin for international taxationVol. 80(9/10)
Reduced inequalities, Peace, Justice and strong institutions
Openalex Percentile: Top 3%
Taxation and Legal Issues
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Stepping Back from the Edge: Australia Retreats from Proposed Domestic Law Changes that Sought to Override Its Tax Treaties — Michael Dirkis · Bulletin for international taxation (2026) | TGRS Research Map | TGRS