Coca-Cola Could Owe $2.6 Billion in Transfer Pricing Dispute (1)

Coca-Cola Co.‘s transfer pricing dispute could cost it $2.6 billion in taxes, the US Tax Court has determined.

The government assessed that much in unpaid deficiencies for the years 2007 to 2009, according to filings at the US Tax Court Wednesday, including $837 million in 2007, $844 million in 2008 and $923 million in 2009. That’s on top of interest that has yet to be assessed, according to the filing.

The company has been contesting a transfer-pricing adjustment in Brazil. The government said the company’s affiliates hadn’t paid enough for its intangible property—like trademarks, brand names, and secret formulas—to ...