Transfer Pricing Services: Insights from Thomson Reuters Checkpoint on Coca-Cola’s IRS Dispute

Thomson Reuters Checkpoint recently published an article featuring Justen Ghwee, examining the 11th Circuit’s review of Coca-Cola’s transfer pricing dispute with the IRS.

Ghwee, international tax director at Kaufman Rossin, called the dispute “a reminder that transfer-pricing positions are living obligations.” He explained that Coca-Cola’s multi-billion-dollar exposure built up over nearly two decades because the same disputed methodology was carried forward year after year without being revisited. Comparables, functional profiles, and market conditions shift over time, he noted, so documentation prepared years earlier may no longer support a company’s current allocation.

Transfer pricing positions, closing agreements, and Advance Pricing Agreements aren’t permanent protections — once these agreements lapse, the underlying methodology is no longer shielded from IRS challenge. Companies with cross-border operations should treat transfer pricing documentation as a living process, updating studies annually to reflect changes in facts and controlling law rather than relying on a position that hasn’t been revisited in years.

Read the full article in Thomson Reuters.

Want to explore how evolving transfer pricing rules could affect your business? Connect with our Transfer Pricing Services team to learn more.