Australia vs PEPSICO: JUDGMENT
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CASE SUMMARY:
This case, decided by the Federal Court of Australia on 30 November 2023, addressed key taxation issues involving royalty withholding tax and diverted profits tax in the context of multinational enterprises (MNEs).
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CASE SUMMARY:
The case of Canada v. General Electric Capital Canada Inc. (2010 FCA 344) revolved around whether guarantee fees paid by GE Canada to its parent company, GECUS, adhered to the arm’s length principle under Canadian tax law. GE Canada claimed deductions for these fees in its income calculations for the 1996–2000 taxation years.
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