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

Authors

• Reuven S. Avi-Yonah, University of Michigan Law SchoolFollow
• Gianluca Mazzoni

Document Type

Article

Publication Date

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.

Recommended Citation

Avi-Yonah, Reuven S. and Mazzoni, Gianluca, "Coca Cola: A Decisive IRS Transfer Pricing Victory, at Last" (2021). Public Law & Legal Theory Working Papers. 166.
https://repository.law.umich.edu/pub_law_archive/166