# Tax authorities are expanding and refining their traditional monitoring functions.

*business · news · 2026-04-30 · Bloomberg Tax News*

## Key points

- Mexico increased transfer pricing audit revenue by 367% from 2019 to 2024, reaching $6.1 billion.
- PepsiCo won the Australian High Court case, as payments for concentrate weren't deemed disguised royalties.
- The majority's decision stressed arm's length pricing and distinct contracts as decisive against re-characterization.
- Australia’s diverted profits tax requires a 'reasonable alternative postulate', not merely theoretical counterfactuals, to apply.
- Australia can consider entities 'associated' based on substantial economic influence, aside from formal ownership ties.

**Companies:** PepsiCo
**Countries:** United States, Australia, Mexico, Germany, Spain, France, Belgium, Japan, China

[Read the full story on Bloomberg Tax News](https://news.bloombergtax.com/daily-tax-report/why-royalty-disputes-are-rising-in-global-taxation-pepsico-case)

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