Preventing Tax Treaty Overrides

“Tax treaty overrides are improper, and something should be done about it”

Despite this pronouncement against tax treaty override - a recommendation of the Council of the Organisation for Economic Co-operation and Development (OECD) in 1989, countries that could override their treaties have continued to do so.

In this seminar on March 31st 2022, Professor Craig Ellife explored solutions to the tax treaty override problem suggesting the solution lies in the hands of the judiciary.