PepsiCo Wins Landmark Royalty Tax Dispute in Australian High Court
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PepsiCo has won an appeal in a long-running royalty tax dispute with the Australian Taxation Office.
In a 4-3 majority judgment in Commissioner of Taxation v. PepsiCo, Inc [2025] HCA 30 (13 August 2025) , the High Court of Australia upheld the decision of the Full Federal Court in June 2024, which ruled that royalty withholding tax was not payable on payments by an Australian bottler for beverage concentrate, and dismissed the alternative that the transaction would be subject to diverted profits tax (see Australia's High Court Grants Tax Authority Special Leave to Appeal PepsiCo Decision (18 November 2024)).
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