PepsiCo and Stokely-Van Camp, US-resident entities, licensed intellectual property to an Australian bottler without charging royalties, embedding value in concentrate prices paid to a local subsidiary. The Australian Commissioner assessed withholding tax on part of those payments as royalties and invoked general anti-avoidance rules. Australia's High Court ruled in favour of the taxpayer in August 2025, rejecting both the royalty characterisation and the tax avoidance grounds ... Read more