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Jill Weise, Managing Director and Global Head of Duff & Phelps’ Transfer Pricing practice, was featured in a recent Bloomberg Tax article titled, “Coca-Cola Tax Court Loss Reminds Companies to Watch IP Valuation.” The article covers the IRS’ U.S. Tax Court win on November 18, 2020 against Coca-Cola Co. concerning a transfer pricing method the company used to license intangibles.
Given the string of high-profile cases for the IRS in recent years, Jill says practitioners can expect more transfer pricing cases. She adds, “I think there’s going to be certainly a trend around a desire to litigate, if necessary, large transfer pricing matters.”
The ruling highlights the importance of how multinational companies account for profits from intangible property. Considering this takeaway for taxpayers, Jill commented, “When looking at your transfer pricing and thinking about where you think the value is along your value chain, do your legal agreements and arrangements actually tie to that perception of value creation?”
Read the full Bloomberg Tax article here.
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Transfer Pricing
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Economic review, analysis of proposed settlements and objective expert testimony in litigation.
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Value a range of intangible property, functions and other interests for tax purposes.
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Valuation and strategic implementation of financing arrangements covering loans, guarantees, cash pools and preferred equity.
Transfer Pricing Global Compliance Services
Global and local transfer pricing documentation, benchmarking and Country-by-Country reporting compliance.
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Enhance internal strategic reviews, implementation strategies and assistance in evaluating planning structures and third-party tools.
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Duff & Phelps’ Transfer Pricing Strategic Planning Services are designed to assist companies when setting up new operations, integrating new acquisitions and divesting existing business lines.
