The influence of domestic tax reviews on Australia's network of international tax treaties

The academic writing of Professor John Taylor on double tax treaties, particularly his meticulous documenting of the history of Australia's tax treaty network, is well known to international tax scholars. In honour of his contribution to this field of literature, we humbly attempt to contribute to the historical analysis of Australia's tax treaty network by testing and documenting the influence of domestic tax reviews conducted since 1999 on tax treaties negotiated or renegotiated in Australia over the same period. In the last 25 years, three significant reviews have extended recommendations beyond domestic tax reform to propose policy changes to the international tax treaty network. The Review of Business Taxation in 1999, the Board of Taxation's Review of International Taxation Arrangements in 2002-2003, and the Australia's Future Tax System review in 2010 made recommendations specifically relating to the tax treaty network. Between 1999 and 2023, the 25-year period of this study, Australia signed 33 tax treaties and protocols, thereby providing an ideal setting for examining the influence of tax reviews on tax treaty policy. This article examines the recommendations from the three reviews and considers their influence on Australia's tax treaty network. It notes the exemplary work of John Taylor in the analysis of the history of Australia's tax treaty policy and practices and provides a recommended approach to a future review of Australia's tax treaty network, concluding that a comprehensive review is not only warranted but long overdue.