Doctor John Azzi

Doctor John Azzi

Senior Lecturer,
School of Law


I joined Western Sydney University in July 2010 after having practised as a barrister from Wentworth Chambers for almost 10 years. My areas of practice were mainly appellate advocacy, administrative law, immigration law, commercial law and taxation law.

Prior to joining the Bar, I worked as a tax adviser with Deloittes, Sydney (1989-1992); a Senior Research Associate with the International Bureau of Fiscal Documentation (IBFD) in Amsterdam (1995-2000) and a consultant to the Australian Taxation Office, where I also sat as a member of the Litigation Panel (2000-2001).

I have also taught tax law at UNSW (ATAX) and UWS (1993-1995), Robert Kennedy College, Zurich (1998-2004) and the International Tax Academy, Amsterdam (1996-1998).

I was awarded a Doctor of Juridical Studies (SJD) from the University of Sydney in 1997. My thesis examined how Australia's then newly introduced controlled foreign company (CFC) regime operates to protect Australia's domestic tax base, comparing it with the US and New Zealand equivalents.

I have published over 30 articles in leading international and national journals, including Law Quarterly ReviewBritish Tax ReviewMelbourne University Law ReviewUNSW Law JournalAustralian Tax ForumAustralian Tax ReviewMonash University Law Review and Australian Law Journal. And have had letters to the editor published in the Financial Times, London. I have also presented at many national and international conferences.

My research output explores the role of courts in ensuring administrative accountability. In particular, the impact of developments in administrative law, equity and constitutional law in protecting the rights of taxpayers to seek judicial review of taxation decisions notwithstanding the statutory mechanism for overturning an excessive tax assessment. My other research interest focuses on international taxation, specifically the complicating and costly role of domestic courts in resolving tax trearty-based disputes and how best to ensure the uniform interpretation of international obligations.

This information has been contributed by Doctor Azzi.


  • SJD University of Sydney
  • LLB University of Sydney
  • BEc University of Sydney

Professional Memberships

  • CTA (Taxation Institute of Australia) (1989)
  • New South Wales Bar Association (2001 - 2028)


  • Highly Commended Tax Research Paper 2019-01-18

Organisational Unit (School / Division)

  • School of Law


  • School Research Committee
  • OPSS Support for Research Working Group


Phone: (02) 9685 9452
Location: EKA.G.05

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Previous Teaching Areas

  • LAWS3070 Taxation Law, 2022
  • LAWS4003 Advanced Taxation Law, 2022


Journal Articles

  • Azzi, J. (2023), 'Australia's tax integrity measure targeting payments for intangibles by multinational groups overreaches and gives cause for concern', Bulletin for International Taxation, vol 77, no 11 , pp 496 - 505.
  • Azzi, J. (2022), 'Judicial review and the tax assessment-making process', UNSW Law Journal, vol 45, no 1 , pp 251 - 284.
  • Azzi, J. (2022), 'Is appointing court leave required to sue a court-appointed liquidator?', Insolvency Law Journal, vol 30, no 2 , pp 88 - 106.
  • Azzi, J. (2022), 'Why leave to sue a court-appointed liquidator is unnecessary and unconstitutional', Commercial Law Quarterly, vol 36, no 4 , pp 4 - 17.
  • Azzi, J. (2021), 'The allocation of multinational business income : reassessing the formulary apportionment option', Australian Tax Review, vol 50 , pp 142 - 147.
  • Azzi, J. (2019), 'Preserving the constitutional function of courts and increasing confidence in the tax system : time to reconsider Futuris', Melbourne University Law Review, vol 43, no 1 , pp 44 - 92.
  • Azzi, J. (2019), 'Tax certainty and taxation of international pension funds : the complicating and costly role of domestic courts', Australian Tax Forum, vol 34, no 4 , pp 707 - 741.
  • Azzi, J. (2018), 'The binding rulings regime and the assessment process', Australian Bar Review, vol 45, no 2 , pp 163 - 182.
  • Azzi, J. (2018), 'Impact of the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting on the taxation of fiscally transparent entities under the Australia-UK Double Tax Agreement', British Tax Review, vol 5 , pp 556 - 588.
  • Azzi, J. (2017), 'Avoiding unfairness : a case for estopping the Commissioner of Taxation', Australian Tax Review, vol 2017, no 46 , pp 242 - 270.
  • Azzi, J. (2016), 'Practical injustice in the context of private tax rulings', University of New South Wales Law Journal, vol 39, no 3 , pp 1096 - 1126.
  • Azzi, J. (2015), 'Limiting abuse of administrative power and enhancing economic welfare', Taxation in Australia, vol 49, no 9 , pp 544 - 546.
  • Azzi, J. (2015), 'Domestic Legislation and Australia's International Obligations', The Law Quarterly Review, vol 131 , pp 525 - 531.
  • Azzi, J. (2015), 'The High Court has an opportunity to reverse the dangerous and unwise precedent set by the Federal Court in FCT v Macoun', Revenue Law Journal, vol 25, no 1 , pp 1 - 6.
  • Azzi, J. (2011), 'Prosecuting Court-Appointed Liquidators in Non-Appointing Courts: A case for overturning outdated law', Monash University Law Review, vol 37, no 2 .
  • Azzi, J. (2011), 'Judicial Review of the Accountants' Concession: A case for improving tax administration and accountability', Revenue Law Journal, vol 21, no 1 .
  • Azzi, J. (2004), 'Plaintiff's Rights of Recovery not Extinguished', Law Society Journal, vol 42, no 8 , pp 56 - 59.
  • Azzi, J. (2003), 'Challenging transfer pricing determination in light of Daihatsu', Tax Specialist, vol 7, no 2 , pp 69 - 82.

Conference Papers

  • Azzi, J. (2019), 'Preserving the constitutional function of courts and increasing confidence in the tax system : time to re-consider Futuris', Australasian Tax Teachers Association. Annual Conference, Perth, W. A..
  • Azzi, J. (2016), 'Estopping the Commissioner of Taxation to ensure administrative accountability', Australian Institute of Administrative Law. Conference, Brisbane, Qld..

My current research focus explores the intersection between public law, constitutional law and taxation law with a view to promoting and ensuring accountability in decision making and efficiency in treaty interpretation and dispute resolution.  I am also separately reasearching the defence of provocation in relation to dog attacks under the Companion Animals Act 1989 (NSW).

This information has been contributed by Doctor Azzi.


Title: Not gay enough: the bizarre hoops asylum seekers have to leap through
Description: Good Weekend 8 December 2017
Title: Open justice vs secret evidence
Description: Radio National 17 March 2009

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