Clark Armitage Addresses Economic Implications of Coke Ruling at NABE Transfer Pricing Symposium

07.20.2021

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

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