Coca-Cola’s Brand Pricing for Offshore Affiliates Knocked by IRS

Coca-Cola Co.'s pricing of its brands and formulas when licensing them to foreign subsidiaries is flawed and results in artificially low taxation, the US told a federal appeals court Monday.

The US multinational soft drink company has estimated that it could owe $12 billion or more if it loses its transfer pricing case against the IRS, currently on appeal before the US Court of Appeals for the Eleventh Circuit. The government defended its tax adjustments against Coca-Cola, accusing the business of grossly undervaluing its intellectual property to underpay tax.

“Legal entitlement to a perpetual windfall is not a real thing,” ...