The Australian Taxation Office (ATO) published a Decision Impact Statement on 19 March 2025 regarding the High Court decision in PepsiCo Inc v Commissioner of Taxation, which was issued in August 2025. As previously reported, the ATO had appealed to the High Court an earlier decision of the full Federal Court of Australia, which found that payments made by Schweppes Australia to purchase concentrate to make beverages from PepsiCo did not include any component that was a taxable royalty for…