Untangling royalty withholding tax: the Pepsico decision and implications for ATO guidance on software payments

Webinar: Join Julian Cheng, Tax Partner, Gilbert+Tobin, for a one-hour LESANZ webinar unpacking the landmark High Court decision in Commissioner of Taxation v PepsiCo Inc [2025] HCA 30 and the Australian Taxation Office’s latest guidance on software payments and royalty withholding tax obligations.

This webinar will provide attendees with clarity on:

  • The ATO’s current guidance on characterisation of software payments of royalties including Draft Taxation Ruling TR 2024/D1 and Draft Practical Compliance Guideline PCG 2025/D4;
  • Key takeaways from the Pepsico decision and what the decision means for the ATO’s guidance;
  • Drafting of SaaS, technology and distribution agreements having regard to the ATO’s views on software payments.

This session will provide lawyers, corporate counsel, and tech companies with practical insights in relation to software payments and royalty withholding tax. There will be an opportunity for Q&A over the course of the session.


Event details: Wednesday 5 November 2025

Via: 

Zoom - online

Time:

12:30pm - 1:30pm presentation AEDT

Seminar Pricing

$free LESANZ member
$25 non-member

The speaker

Julian Cheng, Partner | Gilbert + Tobin

  
When
11/5/2025 12:30 PM - 1:30 PM
AUS Eastern Daylight Time
Where
Webinar via Zoom hosted by LESANZ Zoom links will be provided by the Secretariat Online
Spots available
Registration
Registration is closed. Please contact the Secretariat for late registrations by email