Tax Court Sides With IRS In $3.3B Coke Transfer Pricing Row

Law360 (November 18, 2020, 3:59 PM EST) -- Coca-Cola Co. lost its long-running $3.3 billion transfer pricing dispute with the Internal Revenue Service on Wednesday when the U.S. Tax Court found the agency did not abuse its discretion in reallocating royalty income from foreign affiliates.

The IRS has said Coca-Cola undervalued the intangible assets it licensed to regional subsidiaries from 2007 to 2009, and owes $3.3 billion in additional taxes. (AP Photo/Jeff Chiu)

The court affirmed the IRS' actions and blasted Coca-Cola's pricing for its famed branding trademarks and other intangible assets for the 2007-2009 tax years, which created an uneven dispersal of profits and ran in the face of...

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