Consumer Bites: Episode 4 – Cross-border royalty arrangements

In our fourth vlog of the Consumer Bites Series, Jun Au discusses the Australian Taxation Office's (ATO) increased focus on cross-border royalty-related transactions. It highlights a draft ruling, TR 2024/G1, that changes the ATO's view on payments under software distribution arrangements. The vlog also covers the PepsiCo case where the Federal Court ruled that PepsiCo was liable for royalty withholding tax (this judgement was later overturned in by the Full Federal Court). These developments suggest multinational enterprises in Australia may face more scrutiny over their intellectual property arrangements.