ATO PepsiCo DIS
The 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 marked up in yellow what I believe the DIS tells us about the ATO’s likely attitude in these points. The ATO does not invite comments on the DIS but does ask for notification “of consequences it may not have identified” by 1 May 2026.