First Look: US Tax Court rules in favor IRS in Coca-Cola transfer pricing dispute

The US Tax Court handed a big win to the IRS on November 18 in a transfer pricing dispute with Coca-Cola.

At issue was the intercompany royalties due to Coca-Cola from its foreign affiliates for the use of US owned intangible assets. On account of this dispute, the IRS increased the beverage company’s taxable income by about $9.6 billion for 2007–2009.

MNE Tax will be publishing an in-depth look at this decision written by a transfer pricing expert shortly.