Tax partner Shaun Cartoon was invited by international business news agency Bloomberg to analyse last week’s ruling by the High Court in the long-running royalties and diverted profits tax dispute between the ATO and PepsiCo Inc.
The Court delivered a landmark 4-3 decision in favour of the company which, according to Shaun, demonstrates that “the Australian Taxation Office can’t wish a royalty into being where none exists”.
“It is a win for freedom of contracting and a dead end for the ATO after many years of battle.”
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