Ryan Finley of Tax Notes and Robert Goulder have exchanged ideas on the U.S. Tax Court’s determination of the Coca-Cola case. Finley believes that this company’s $12 billion transfer pricing dispute is an excellent opportunity for multi-national companies to understand the shifting business dynamics and their general impact.
Goulder and Finley as experts
Goulder happens to be a contributing editor that has over the years worked with Tax Notes International. His specialties range from a deep understanding of the digital economy and base erosion and profit shifting.
Finley is a legal reporter that understands transfer pricing from a broader context of meaning. He also has a deep interest in international tax issues. Finley and Goulder open the public’s eyes to the court’s decision and Coca-Cola’s take on the matter.
The two discuss the company and the warning it issued recently on taxpayer complacency. Over the years, the tax court has become a battleground between Coca-Cola and the Internal Revenue Services. The court has constantly ruled in favor of one side, but that story might be changing this time around.
The discussion
Coca-Cola might not continue keeping its clean sheet of wins because the IRS might be taking the day. The company isn’t losing gracefully, considering that it vowed to stage a strong appeal. It is a shift that points to the multi-national co-operations reserving fears over the loss of significant profits if matters go south in courts.
Coca-Cola operates elaborately, and that is considering its many supply points spread out across the world. The company’s overseas affiliates’ network starts by getting a license from Coca-Cola before they undertake the production activities. However, the brand name, trademark, and everything else that makes its products stand out to remain in the United States.
The dispute doesn’t only involve Coca-Cola beverage. The matter involves a large family of drinks, including Fanta, Sprite, and others. The company insists that the ownership of the IP won’t change.
Therefore, it will continue being in the U.S. The court asserts that the economic substance isn’t something that should become a subject of discussion or argument. It warns the taxpayer from raising such issues at all. The court dismisses any disputes that might crop up as pointless.
