Coca Cola: A Decisive IRS Transfer Pricing Victory, at Last


By Reuven S. Avi-Yonah and Gianluca Mazzoni

Coca Cola v. Commissioner (Tax Court, Nov. 18, 2020) is the first decisive IRS victory in a major transfer pricing case since 1979. If the outcome is not reversed on appeal, this will mark an important shift in transfer pricing litigation in the US, and perhaps indicate that the IRS could win some of the other major pending cases, like the one against Facebook.

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By Reuven S. Avi-Yonah and Gianluca Mazzoni, posted on Tuesday January 12, 2021

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