11:56 AM EDT, 08/28/2025 (MT Newswires) -- Coca-Cola (KO) told a US federal appeals court on Wednesday that the Internal Revenue Service was "inconsistent" in its treatment of Coca-Cola's overseas operations, accusing the IRS of trying to "game" US tax laws to uphold a tax court decision that could potentially cost the company billions of dollars in tax liability.

In a recent filing with the US Court of Appeals for the Eleventh Circuit, the company said the IRS applied a transfer pricing method that ignores billions of dollars in marketing investments and gives no credit for licenses held by Coca-Cola's overseas subsidiaries.

The company said it "carefully adhered" to the transfer pricing method that was "repeatedly blessed" by the IRS.

"Far from seeking to evade its tax obligations, Coca-Cola carefully structured its operations to adhere to a method that the IRS had repeatedly blessed and, in fact, accepted for numerous other Coca-Cola supply-point companies during the very tax years at issue," Coca-Cola said in a court filing.

The company also said the IRS improperly compared its supply-point companies, which hold legal rights to manufacture and sell concentrate, with bottlers, calling the comparison "flawed" and one that fails to account for different business risks.

The company has petitioned the court to reject IRS's "extreme position" and overturn the tax court's earlier decision, according to the filing.

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