by SunCoast Media | Aug 19, 2026 | Uncategorized
Australian Case updateTreaty 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...
by SunCoast Media | Aug 19, 2026 | Uncategorized
ATO PepsiCo DISThe pursuit of “embedded royalties” continues To help understand the ATO PepsiCo Decision Impact Statement (DIS) which has just issued, I have set out below my original 2025 summary of the High Court Judgement. Which is still relevant. And then I have...
by SunCoast Media | Aug 19, 2026 | Uncategorized
Australian corporate tax: PepsiCo and Oracle Last week, the Deputy Chief Tax Counsel of the Australian Tax Office said that companies “should not expect that the PepsiCo decision would lead to substantive changes” to the draft Taxation Ruling TR2024/D4. In the same...
by SunCoast Media | Feb 6, 2025 | Uncategorized
Pleadings in PepsiCo filed in the High Court Both parties have now filed their primary pleadings in the High Court The story so far Last Thursday PepsiCo filed its pleadings in response in the High Court appeal. We are expecting a hearing in the first half of the...
by SunCoast Media | May 20, 2024 | Newsletter
What happened at the PepsiCo appeal hearing a week ago? Argument in the Full Federal Court appeal was conducted on 8-10th May. Many clients have already started work to identify the intellectual property used in their Australian operations which might be affected, and...
