Australian Case update
Treaty shopping & Coca-Cola royalty disputes
Australia’s first “treaty shopping” case is understood to have been filed in the Federal Court. It disputes the inclusion of more than AUD$4bn in income, and the levying of interest of about a quarter of a billion dollars. It appears to involve companies associated with the European Vitol petrolium group and the Abu Dhabi Investment Council. This will be a significant precendent if it proceeds to trial. And Coca-Cola finds itself in a similar situation to PepsiCo, a dispute with the ATO over distributor payments.