Barnes Dennig Transfer Pricing After Tax Reform and COVID-19 120920 - BD | Page 8

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IT ’ S THE REAL THING

The IRS Wins in Tax Court Against Coca-Cola 2007-2009

• Coca-Cola ( US ) licenses its trademarks , product names , logos , patents , formulas , and manufacturing processes

• Foreign affiliates utilize the IP to sell concentrate to bottlers

• IRS audited transactions with Brazil , Costa Rica , Egypt , Ireland , Mexico , and Swaziland

• US Tax Court released its decision on November 18 , 2020

• IRS issued over $ 9 billion in transfer pricing adjustments

• Taxes due $ 3.2 billion

• Argument – foreign subsidiaries earned excessive returns