Gauging PepsiCo Tax Win’s Impact: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week all eyes turned to Australia as the High Court down under handed PepsiCo a big win in its long-running tax dispute.

OK, so it’s not exactly a transfer pricing case, but the PepsiCo ruling has big implications for related-party cross-border transactions, particularly those that include royalties or that might be subject to Australia’s whopping 40% tax on diverted profits.

The decision is the latest setback to the Australian Taxation Office—likely sending the agency back to the drawing board for a controversial draft ruling on the ...