Commissioner of Taxation v PepsiCo Inc, [2025] HCA 30

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Summaries

Summary Under

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...

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Words and Phrases

Summary Under

meaning of “consideration for”

In finding that the purchase price paid by an Australian bottler for concentrate could not be recharacterized as a royalty, which under the...

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Words and Phrases