Coca-Cola Slams IRS ‘Bait and Switch’ in Transfer-Pricing Appeal

Coca-Cola Co. asked a federal appeals court Tuesday to throw out lower-court decisions on its transfer-pricing methods that stand to cost it billions of dollars, saying the company has been the victim of an IRS “bait and switch.”

The IRS was “arbitrary, capricious, and unlawful” in switching a transfer-pricing method that Coca-Cola had long used and retroactively imposing a different method that led to billions of dollars in added taxable income for Coca-Cola and thus higher tax bills, the company said in an appeals brief filed with the US Court of Appeals for the Eleventh Circuit.

Transfer pricing refers ...