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Australian Federal Court finds embedded royalty in arm's-length contract

|Tax Alerts, Information Reporting, Natio ...|Australia
Australia

  • The Court found that a royalty was paid, notwithstanding that the contract had not expressly provided for it.
  • Royalty withholding tax was found to be applicable.
  • The Court found that diverted profits tax (DPT) elements were satisfied, but DPT was not applied due to Court's conclusions on royalty withholding tax.
  • The decision is expected to be influential in actions of Commissioner of Taxation going forward.

On 30 November 2023, the Australian Federal Court (Court) delivered a decision in PepsiCo, In…

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