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.
Authors
- Michael Dirkis
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