Insights

A&M Newsletters
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Thought Leadership

Analysis of Recent Full Federal Court Decision in Australian Tax Case

April 8, 2024
In Minerva Financial Group Pty Ltd v Commissioner of Taxation [2024] FCAFC 28, the Full Federal Court reversed the Federal Court’s decision in finding that Australia's general anti-avoidance rules (Part IVA) did not apply to income distributions made by a trust within a stapled group structure. What rationale did the Federal Court provide for their decision?
Thought Leadership

Controlling the Sales Tax Function: A Human and Digital Partnership

April 5, 2024
While sales tax automation solutions are handy tools that have changed how a company’s finance organization complies with sales tax, the human component remains irreplaceable. How does human oversight affect the management of the sales tax process across various areas such as sales tax nexus, exemption certification management, sales tax audit management, and more?
Thought Leadership

Innovate, Integrate, Excel: Leading Hybrid Teams to Triumph

April 3, 2024
In today’s work environment, the prevalence of hybrid teams has steadily risen in the public accounting world. This blend of in-office and remote work presents unique challenges and opportunities. How are leadership strategies changing as the accounting profession evolves?
Thought Leadership

An analysis of Pepsi’s tax case in Australia: A look at ‘embedded royalties’ and diverted profits tax

April 2, 2024
In a recent landmark decision, Moshinsky J of the Federal Court of Australia ruled that a portion of payments made under exclusive bottling agreements made by Schweppes Australia Pty Ltd (SAPL), an Australian company owned by Asahi Breweries, was subject to royalty withholding tax (RWT) to the extent that they related to use of PepsiCo group’s intangible assets held by its US-based companies. The case revolves around Exclusive Bottling Agreements (EBAs) entered into by PepsiCo, Inc (PepsiCo) as owner of the Pepsi and Mountain Dew brands and Stokely-Van Camp, Inc (SVC) as owner of the Gatorade brand with Schweppes Australia Pty Ltd (SAPL), an Australian company owned by Asahi Breweries, as “Bottler”.
Thought Leadership

Why Data Cleanup Fails – Part Three: Process

April 2, 2024
In the third edition of our "Why Data Cleanup Fails" insight series, A&M’s Joe Shepley and Christopher Hockey explore the critical role of process in data cleanup and how building strong processes can prevent inconsistent decision making and increased data risk.
Thought Leadership

Unlocking Private Equity Opportunities in the Facility Services Sector

April 2, 2024
Companies in the Facility Services sector — such as janitorial, HVAC, alarm security, fire protection and window washing companies, among others — represent a highly attractive target for private equity (PE) investors due to its recurring revenue streams, long contract terms, and essential service nature.