IFA Australia: “Pop”-Up – Lunchtime Webinar

“Royalty-free licenses” survived tax challenge in the High Court’s much-awaited decision in Commissioner of Taxation v PepsiCo Inc [2025] HCA 30.

The decision provides guidance and raises further questions about the scope of the royalty withholding tax and diverted profits tax. Our expert panel will explore international tax law developments on royalties, goods/IP transactions, related party structures, and wholly digital products and services.

Chair:
Chloe Burnett SC, Sixth Floor Selborne Wentworth Chambers

Speakers:

Jerome Tse, Partner, King & Wood Mallesons
Gary Sprague, Partner, Baker & McKenzie, Palo Alto, USA
Peter Walmsley, Deputy Chief Tax Counsel, Australian Taxation Office