Embedded Royalties and Art 12 of the Australia-United States Tax Treaty: The Case of PepsiCo

From 7th to 9th May 2025, the Vienna University of Economics and Business Institute for Austrian and International Tax Law hosted the annual “Tax Treaty Case Law around the Globe 2025” Conference. Reports on PepsiCo v FCT and Oracle v FCT were contributed by Professor Kerrie Sadiq (QUT) and Professor Michael Dirkis (University of Sydney). A copy of the PepsiCo presentation can be found here.