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.
Law and Economics
Date of this Version
Working Paper Citation
Avi-Yonah, Reuven S. and Mazzoni, Gianluca, "Coca Cola: A Decisive IRS Transfer Pricing Victory, at Last" (2021). Law & Economics Working Papers. 201.