Coca Cola's intercompany royalty rate : an intermediate view

Resource Information

The work Coca Cola's intercompany royalty rate : an intermediate view represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Coca Cola's intercompany royalty rate : an intermediate view

Creator

• McClure, J.H

Subject

• case law
• intercompany transaction
• marketing intangibles
• CUT method
• royalties
• transfer pricing
• transfer pricing adjustment
• profit methods

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

Geographic coverage

International

Language note

English