PepsiCo, Inc v Commissioner of Taxation, [2024] FCAFC 86

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Summaries

Summary Under

concentrate purchases by an Australian soft drink bottler could not be recharacterized as trademark royalties for withholding tax purposes

A U.S. company (PepsiCo) entered into an “exclusive bottling appointment” (“EBA”) with an independent Australian bottling company (the...

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Summary Under

sales proceeds for concentrate paid to a Pepsi Australian subsidiary could not be characterized as trademark royalties paid to Pepsi

A U.S. company (PepsiCo) entered into an “exclusive bottling appointment” (“EBA”) with an independent Australian bottling company (the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

there can be no payment by direction unless there is an antecedent obligation by the creditor to the third party

A U.S. company (PepsiCo) entered into an “exclusive bottling appointment” (“EBA”) with an independent Australian bottling company (the...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.