Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals

Law360 (February 19, 2021, 2:50 PM EST) -- On Nov. 18, 2020, the U.S. Tax Court ruled that Coca-Cola Co. owes more than $3.3 billion in taxes due to undercharging affiliates for the right to use Coca-Cola's intangible property during the examination period between 2007-2009.

Court decisions of this magnitude provide significant learning opportunities for both taxpayers and practitioners — even when the key issues may appear quite specific to a certain fact pattern, industry or type of intercompany charge. The court's opinion provides careful and detailed insights into future Tax Court rulings that can be interpreted broadly.

While it is anticipated that Coca-Cola will likely appeal this decision...

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