‘Stay Away’: Full Federal Court backs Oracle in significant decision

As outlined by James Alsop, Shalini De Silva, Sakshi Mathur and William Ho, the Full Federal Court has allowed Oracle’s appeal to stay domestic tax proceedings.

The Full Federal Court (Hespe, Button and Younan JJ), on 21 October 2025, unanimously allowed Oracle's appeal, overturning Perram J's earlier decision to refuse to stay proceedings in favour of MAP with Irish authorities. With no public interest factors weighing against a stay, the Full Court determined that the Double Tax Agreement ('DTA') and Multilateral Instrument ('MLI') supported pausing proceedings to preserve a taxpayer's right to Mutual Agreement Procedure ('MAP'), including arbitrat...

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Authors: James Alsop, Shalini De Silva,

Published Date: 28 October 2025