I think it actually misrepresents Google's statements too - the ACCC response makes it sound like Google are saying they would be required to charge for their services, but Google actually said that the code might make it no longer worthwhile for them to provide their services for free in Australia.

It would have been fair to say that part of Google's statement is probably an exaggeration, but the ACCC instead muddies the waters by rebutting something Google didn't actually say...