Our Global Tax Policy and Controversy (TPC) Group at A&M Tax is excited to introduce a new podcast series, “A&M Tax Talks: Tax Policy Updates” which delivers the latest insights and our views on the evolving tax policy landscape. This series explores timely and relevant topics, highlighting their impact on organizations and key considerations for effective planning and strategic decision-making.

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Episode 2

17 September 2025

Jayde Thompson & Shahzeb Panhwar: PepsiCo – Rethinking Royalties and Transactions

In this episode, Jayde Thompson, Corporate International Tax Managing Director, and Shahzeb Panhwar, Transfer Pricing Lead - Australia, unpack the Australian High Court’s landmark decision in PepsiCo, which has major implications for the tax treatment of cross-border payments involving intellectual property use. They explore how the Court’s rejection of the Australian Taxation Office’s embedded royalty argument reaffirms the primacy of arm’s length commercial arrangements in determining tax characterisation. 

Episode highlights:

• Key facts of the PepsiCo arrangements between the parties
• Royalty withholding tax and Diverted Profits Tax (DPT) implications
• Key observations and insights coming out of the decision: commercial substance, contractual arrangements, and arms-length dealings
• Takeaways for multinationals managing cross-border IP and royalty payments

Listen to the podcast below.

Episode 1

8 September 2025

Bruno Aniceto da Silva: G7 Side-by-Side (SbS) Arrangement

In this episode, Bruno Aniceto da Silva, Senior Advisor – Global Tax Policy & Controversy, brings to you insights about the recently announced G7's side-by-side (SbS) arrangement and discusses its implications for multinational enterprises.

Here is a brief outline of this episode of the podcast:

• The context of the recent G7 and G20 statements

• How the Net Covered Tax Income (NCTI) interacts with Global Anti-Base Erosion (GloBE) rules

• How SbS may work and may be implemented

• Our A&M Tax Takeaways

Listen to the podcast below.

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