OrbitaxATO Decision Impact Statement on High Court Finding PepsiCo Not Liable to Pay Royalty Withholding Tax Nor Diverted Profits Tax
|Approved Changes|Australia
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 con…