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$3B Tax Trial Will Focus On Royalties, Coca-Cola Says

Law360 (February 8, 2018, 7:08 PM EST) -- Long-standing royalty agreements between Coca-Cola and six foreign subsidiaries will be the company's main focus at trial in its $3.3 billion transfer pricing dispute with the Internal Revenue Service, Coca-Cola said in a 161-page trial brief filed Wednesday at the U.S. Tax Court.

Coca-Cola Co. had used an IRS-accepted royalty agreement from 1996 to 2006 giving foreign licensees 10 percent of gross sales and splitting remaining profits between licensee and company, Coca-Cola said in its brief. The IRS “abandoned” the agreement “without explanation” while continuing to...
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