Commissioner of Taxation v PepsiCo Inc, [2025] HCA 30 -- summary under Paragraph 212(1)(d)
FMV sales proceeds of concentrate paid to an Australian sub of PepsiCo, the trademark licensor, not recharacterized as royalty
A U.S. company (“PepsiCo”) entered into an “exclusive bottling appointment” (“EBA”) with an independent Australian bottling company...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Consideration | meaning of “consideration for” | 422 |