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

[@jamesmcclure5947]

Neither expert provided useful evidence but this issue could have been properly addressed as I noted in "Royalty Rate in PepsiCo v. Commissioner: The Right Answer for the Wrong Reasons", Tax Notes International, January 22, 2024. CUT approaches were not used in the Coca Cola v. IRS case which has similarities to this issue. Something less aggressive than the IRS profits based approach would have led to a conclusion similar to what the Judge ended up with.