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By Antonio WEFFER, Tax Principal, Baker McKenzie Luxembourg
International tax authorities are devoting growing attention to intragroup arrangements involving intangibles. Cross-border IP payments now exceed USD 1 trillion annually, and intragroup transactions account for a substantial share of multinational trade. Backed by BEPS-driven cooperation and improved technological tools, tax administrations are increasingly prepared to challenge the substance of long-standing business models. The recent High Court of Australia decision in Commissioner of Taxation v. PepsiCo, Inc.; Stokely-Van Camp, Inc. [2025] HCA 30 illustrates this shift.
The 4:3 majority ruled in favour of PepsiCo, ending several years of litigation with the Australian...
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