The Resource Coca Cola's intercompany royalty rate : an intermediate view

Coca Cola's intercompany royalty rate : an intermediate view

Label
Coca Cola's intercompany royalty rate : an intermediate view
Title
Coca Cola's intercompany royalty rate : an intermediate view
Creator
Subject
Language
eng
Summary
The article discusses the case Coca Cola Co. v. Commissioner concerning the determination of intercompany royalty rate. Coca Cola sells a lot of concentrate at very high-profit margins so every one percent change in the royalty rate represents a large transfer pricing adjustment. The author notes that this case illustrates the vast array of economic approaches to an oft-seen fact pattern foreign affiliates incurring significant advertising expenses on behalf of a trademark owned by the parent corporation. In this article, he discusses the basic fact pattern and some key financial facts for the 2007-2009 period at issue as well as the various positions taken by Coca Cola and foreign tax authorities over time. The discussion also covers almost every variation of both the Comparable Uncontrolled Transaction (CUT) approach and the various profit-based approaches
Citation source
In: Journal of international taxation. - New York. - Vol. 31 (2020), no. 2 ; p. 30-51
http://library.link/vocab/creatorName
McClure, J.H
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • royalties
  • intercompany transaction
  • marketing intangibles
  • transfer pricing adjustment
  • case law
  • transfer pricing
  • CUT method
  • profit methods
Label
Coca Cola's intercompany royalty rate : an intermediate view
Instantiates
Publication
Label
Coca Cola's intercompany royalty rate : an intermediate view
Publication

Library Locations

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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