ATLANTA — The Coca-Cola Co. on Sept. 17 received a notice from the Internal Revenue Service that claims the multinational beverage company owes about $3.3 billion in taxes, plus interest, for the tax years 2007-09, according to a Sept. 18 Securities and Exchange Commission filing from Coca-Cola.
The Coca-Cola Co. said the I.R.S. assessments are without merit. The company has requested a meeting with the I.R.S. Chief Counsel and said it expects to challenge the I.R.S. notice by filing a petition in the United States Tax Court.
The issue deals with U.S. taxable income in overseas markets. The Coca-Cola Co. in its S.E.C. filing said the dispute largely relates to the appropriate amount of taxable income that the company should report in the United States in connection with foreign licensees regarding the manufacturing, distribution, sale, marketing and promotion of products in overseas markets. Atlanta-based Coca-Cola said it has followed the same transfer pricing methodology for the licenses since a 1996 closing agreement with the I.R.S. that applied back to 1987.
“The company firmly believes that the assessments (for 2007-09) are without merit and plans to pursue all administrative and judicial remedies necessary to resolve this matter,” Coca-Cola said in its S.E.C. filing.
Coca-Cola said that if the I.R.S. were to prevail, it could impact the company’s financial position, results of operations or cash flows. Shares of The Coca-Cola on the New York Stock Exchange were trading at $39.21 per share on Sept. 21, which compared favorably to an opening price of $38.86 per share on Sept. 18.Such tax issues occur frequently for multinational companies like Coca-Cola, said Robert Willens, president of a tax accounting consultancy in New York, in an Associated Press report. He said such cases typically are settled for a fraction of the assessed amount.