NERA Managing Director Dr. Harlow Higinbotham and former Director Dr. Niraja Srinivasan have published “‘Coca-Cola’ vs. Section 482: Is It Time to Refresh the Regulatory Guidance?” in Tax Management International Journal. The authors use the November 2020 decision by the US Tax Court in Coca-Cola as a case study to illuminate how regulatory guidance refinements by the OECD and other tax authorities diverge from existing US Section 482 regulations. Dr. Higinbotham and Dr. Srinivasan point to several ways the Court’s opinion in Coca-Cola would have been substantially different had it followed best practices derived from new tax guidance from the OECD and other authorities.