The Australian Taxation Office’s attempts to reel in multinational corporations using complex deals and structures to minimise tax has been dealt a blow after beverage giant PepsiCo successfully challenged its bill.

US-based Pepsi disputed an assessment by the Commissioner of Taxation that it owed millions in royalty withholding tax and diverted profits tax over deals with the former Schweppes Australia, subsequently Asahi Beverages, for the 2018 and 2019 financial years.