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

3:15pm - 4:30pm

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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