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HIGH COURT SIDES WITH COCA COLA
The High Court of the USA sided with Coca Cola in a landmark judgement on transfer pricing issues. The pricing of patents were the central focus of the case.
DATE
DISPUTE EVENT
Transfer Pricing of Patents
TOPIC
31 Jul 2022
Section 31
IT234/uytr
Appeal
CASE REFERENCE
High Court of the USA
APPEALED CASE REFERENCE
ref/56/ITA/77
COURT
LAW OR TREATY
Income tax Law
SECTION OR ARTICLE
JURISDICTION
USA
Taxpayer
CATEGORY
Dispute Resolution
DECISION IN FAVOUR OF
COCA COLA
TAXPAYER
In favour of the Appellant Coca Cola, based on lack of evidence of alternative pricing by the IRS.
OUTCOME
ISSUE
The transfer price of patents owned by the US parent and used by subsidiaries in Europe.
REVENUE AUTHORITY
IRS
PUBLIC ENTITY
CASE LINK
SOURCE LINK
DETAILS
Summary of Coca Cola Case
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