Policy analysis reveals expanding domestic anti-avoidance protections in Australian tax treaties, signalling a shift toward preserving source country taxation.
This article examines recent trends in Australia’s tax treaties, focusing on post-BEPS developments and the emergence of “super-savings” provisions. It argues that Australia’s treaty practice increasingly preserves domestic anti-avoidance and evasion laws, narrowing the role of treaties in limiting source country taxation and signalling a shift in treaty policy.
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David Watkins (2026) studied this question.
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