The constitutionality of methods of influence used by the UK in imposing OECD tax reform on Crown Dependencies and Overseas Territories

This article reviews the constitutional arrangements between the United Kingdom (UK), the Crown Dependencies and the Overseas territories (CDOTs) in the context of international tax reform. These reforms occupy a hybrid space between domestic and international affairs, leaving a tension in current constitutional arrangements. It highlights extra constitutional actions by the UK and responses from the CDOTs resulting from this tension. It concludes that the UK’s behaviour amounts to ‘intervention by the back door’, including threats of sanctions in the form of defensive measures and threats from senior politicians. All whilst the UK holds the power to directly intervene in legisdlation. The article ultimately appeals for a constitutional convention wherein the rights and obligations of the parties are properly delineated, providing measurable outcomes and a maximisation of self government whilst protecting the UK’s position as the state responsible for enacting international commitments on the part of the CDOTs.