PepsiCo falls flat for the ATO
Published Date: 20 Sep 2024
The PepsiCo case is one of the more significant tax cases in recent times, and it touches on a number of important considerations for multinationals. It explores what constitutes an embedded royalty for tax purposes, the concept of consideration for the use of intangible assets, and the application of Australia’s diverted profits tax anti-avoidance provisions. This article focuses on the recent decision of the Full Federal Court, which has now been appealed by the Commissioner. The outcome of the Commissioner’s special leave application, and any final High Court judgment, will provide some much needed certainty and clarity around the above issues.
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Details
- Published By: Luke Imbriano FTI, Michael Carroll, Eugenia Kolivos, Craig Boyle CTA, Julia Bolodurina, Cameron Blackwood ATI
- Published On:20 Sep 2024
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