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Big Four accountants attack IRS over ‘capricious’ US tax treatment of Coca-Cola

Deloitte, PwC and KPMG filing in potential $18bn case warns of ‘erosion of confidence’ in fairness of system for companies

Deloitte, PwC and KPMG have launched a scathing attack on the Internal Revenue Service, which they accused of “a pattern of arbitrary, capricious and unreasonable conduct” towards multinational companies that risks eroding confidence in the US tax system.

The three accounting firms made the claims about the US tax authority in a court filing this week supporting Coca-Cola’s attempt to overturn a ruling by the agency that could cost the drinks maker $18bn.

The dispute centres on “transfer pricing” arrangements relating to the allocation of profits between Coca-Cola subsidiaries in different countries. The tax arrangements had been blessed by the other Big Four accountancy, EY, which has audited the drinks maker’s financial statements since 1921.

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