PepsiCo in the High Court of Australia: Last Drinks for the Commissioner of Taxation

On 13 August 2025, the High Court of Australia ruled 4:3 for PepsiCo, holding that payments to an unrelated distributor contained no embedded royalties and that no income was “derived” for withholding tax purposes. In Australia’s first diverted profits tax case, the court also found no tax benefit, with significant implications for multinationals and the Australian Taxation Office’s interpretive approach.

Authors

Publication Details

Journal
Bulletin for international taxation
Published
2026-01-12
DOI
https://doi.org/10.59403/1crss61
Primary Topic
Commonwealth, Australian Politics and Federalism
Type
article
Field-Weighted Citation Impact
0.00
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article

PepsiCo in the High Court of Australia: Last Drinks for the Commissioner of Taxation

Michael Dirkis, Kerrie Sadiq
Bulletin for international taxation
Commonwealth, Australian Politics and Federalism
article

PepsiCo in the High Court of Australia: Last Drinks for the Commissioner of Taxation

Michael Dirkis, Kerrie Sadiq
article en

Abstract

On 13 August 2025, the High Court of Australia ruled 4:3 for PepsiCo, holding that payments to an unrelated distributor contained no embedded royalties and that no income was “derived” for withholding tax purposes. In Australia’s first diverted profits tax case, the court also found no tax benefit, with significant implications for multinationals and the Australian Taxation Office’s interpretive approach.

Bulletin for international taxationVol. 80(2)
Openalex Percentile: Top 92%
Commonwealth, Australian Politics and Federalism
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PepsiCo in the High Court of Australia: Last Drinks for the Commissioner of Taxation — Michael Dirkis, Kerrie Sadiq · Bulletin for international taxation (2026) | TGRS Research Map | TGRS