All rights reserved.įor more detail about the structure of the KPMG global organization please visit. © 2023 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. The information contained herein is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230. Tax Court served up a major victory to the IRS when it upheld the agency's nearly 10 billion transfer pricing adjustment against. KPMG LLP does not provide legal services. This week: share a Coke KO -0.9 decision. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. Coca-Cola and the Mexican tax authorities had agreed on the same formula and Coca-Cola continued to use the pricing-formula in Mexico on the advice of Mexican counsel. ![]() ![]() The case, which had been pending in the Tax Court since 2013, was yet another win for. ![]() The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Coca-Cola had been applying a transfer pricing method called the 10-50-50 since it entered into a closing agreement with the IRS in 198, covering the years 1987 to 1995. The agreement expired in 1995, but Coca-Cola continued to use the model for transfer pricing in the following years. Tax Court released its long-awaited transfer pricing decision in 3M v.
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