U.S. Tax Court Denies Coca-Cola's Request for Reconsideration in Transfer Pricing Case

The U.S. Tax Court issued an order dated 26 October 2021 denying Coca-Cola's request to file an out of time motion for reconsideration in respect of the opinion of the Court issued 18 November 2021 concerning whether the IRS abused its discretion by making transfer pricing reallocations of royalties by employing a comparable profits method (CPM). As previously reported, the relocation was made in respect of income reported from supply points in various countries that produced concentrate used…