business / news / / Bloomberg Tax News
Tax authorities are expanding and refining their traditional monitoring functions.
Mexico increased transfer pricing audit revenue by 367% from 2019 to 2024, reaching $6.1 billion.
KEY POINTS
- 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
Summarized by Newsio from Bloomberg Tax News. How we summarize →