September 2025 Newsletter

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 week the full Federal Court heard Oracle’s appeal, seeking a stay of domestic proceedings while it pursued MAP in its dispute with the ATO.