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PepsiCo savors $363m US tax triumph over IRS
date:Sep 27, 2012
tax regime changes led PepsiCo to transfer ownership of its foreign partnerships (above) from Dutch Antillean to Dutch holding companies in the late 1990s.

Thus, these partnerships passed to the contol of Dutch subsidiaries PepsiCo Global Investments (PGI) and PepsiCo Worldwide Investments (PWI), which were issued new promissory notes by PepsiCo in theUSto fund investments in these markets.

Goeke explained that PepsiCo developed hybrid securities via legitimate tax planning that were classed a

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