PepsiCo, Inc v Commissioner of Taxation - 3.a 7 methods to estimate royalty amount [2023] FCA 1490

[@jamesmcclure5947]

Dana Wright did not understand the issue. So your paragraph 296. The issue was not the intangible profits received by the bottler which of course are near zero. The issue was how much of the third party payment represents the IP value received by Pepsi as producer/seller of syrup. Your discussion unfortunately goes down the rabbit hole Wright followed.