Australia Undeterred by PepsiCo Ruling: Transfer Pricing Report

March 20, 2026, 9:02 AM UTC

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week Australia’s tax office shared thoughts about what its big loss against PepsiCo last year means for future enforcement efforts (not much, it seems). Coca-Cola claps back at the IRS over 3M’s place in the case. And APAs between the US and Ireland are on the rise.

Pepsi loss? What Pepsi loss?

OK, they didn’t go that far, but judging by this week’s decision impact statement the Australian Taxation Office clearly has no plans to let the High Court’s ruling in its long-running dispute with Pepsi derail ...

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