Australia Mulls PepsiCo Decision’s Impact on Software Guidance

Australia’s tax office is considering how its loss at the High Court in a key royalty-tax case involving PepsiCo Inc. will affect its draft guidance on how software makers are taxed.

The Australian Taxation Office is looking at “any broader impact” the PepsiCo ruling may have on the reasoning it laid out in draft rules detailing the tax treatment of certain payments to bring software into the country, the office said in a website update Monday.

The draft rules specifically detailed when those software payments would be treated as royalties subject to withholding taxes. The ATO said last October it ...