From www.austaxpolicy.com: The High Court of Australia reserved its decision on an appeal regarding the PepsiCo case, which examines the applicability of the Income Tax General Anti-Avoidance Rule (Part IVA) in relation to payments made by Schweppes Australia for PepsiCo’s beverages.

The primary issue is whether these payments included a royalty for the use of PepsiCo’s intellectual property, which, if determined as such, would invoke royalty withholding tax.

The outcome could impact foreign multinationals operating in Australia and will assess the effectiveness of the 2013 amendments to Part IVA aimed at addressing tax avoidance.