Summary
After the High Court held 4:3 in Commissioner of Taxation v PepsiCo [2025] HCA 30 that no royalty withholding tax or diverted profits tax applied, the ATO's decision impact statement says it still considers that royalties can be embedded in payments for goods or services and will keep scrutinising related-party arrangements.
What it means for you
Distribution and franchise payments by Australian entities to related IP owners remain an audit focus.
This summary is general information, not legal advice. The outcome of any case depends on its facts; read the source and take advice before acting.
More Australia updates
- ATO loses Bendel appeal on unpaid trust entitlements10 Jun 2026 · High Court of Australia