Coca-Cola, IRS Battle Over Billions: Transfer Pricing Report

Coca-Cola, IRS Battle Over Billions in Court

A Coca Cola ad in Sydney, Australia

Photographer: Brendon Thorne/Bloomberg

Coca-Cola and the IRS will square off in court next week in a case that could cost the beverage giant as much as $20 billion and influence how aggressively the tax agency can enforce transfer pricing rules for multinationals, Michael Rapoport and David Schultz report.

The case is “the Super Bowl of transfer pricing controversy,” Eide Bailly principal Chad Martin said.

Coca-Cola is appealing US Tax Court rulings that side with the IRS over the company’s pricing of transactions with its foreign affiliates—how much they paid for the right to use trademarks, ...