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

8 Pages Posted: 3 Feb 2021 Last revised: 15 Jun 2021

See all articles by Reuven S. Avi-Yonah

Reuven S. Avi-Yonah

University of Michigan Law School

Gianluca Mazzoni

University of Michigan at Ann Arbor - Law School

Date Written: January 12, 2021

Abstract

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.

Keywords: Coca Cola, transfer pricing

JEL Classification: H26

Suggested Citation

Avi-Yonah, Reuven S. and Mazzoni, Gianluca, Coca Cola: A Decisive IRS Transfer Pricing Victory, at Last (January 12, 2021). Tax Notes Federal, Volume 169, Number 11 ■ December 14, 2020, U of Michigan Law & Econ Research Paper No. 21-006, U of Michigan Public Law Research Paper No. 21-006, Available at SSRN: https://ssrn.com/abstract=3764501

Reuven S. Avi-Yonah (Contact Author)

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

Gianluca Mazzoni

University of Michigan at Ann Arbor - Law School ( email )

Ann Arbor, MI
United States

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