Clark Armitage Addresses Economic Implications of Coke Ruling at NABE Transfer Pricing Symposium
Program: Economic Analysis of the Coke Ruling
Event Sponsor: NABE Transfer Pricing Symposium
Some thoughts from the Roundtable with respect to the types of ideas that might be considered for discussion on the panel are:
- Implications from the ruling on the value of controlled licensees’ marketing intangibles (independent of TMs)
- Inferences with respect to the very high royalty rate that is implied by the IRS CPM analysis
- implications for the practical utility of RPSM analyses?
- critiques specific to the IRS comparables (the bottlers) used in their CPM analysis