Coca-Cola has escalated its long-running tax dispute with the Internal Revenue Service to a federal appeals court in Miami, with approximately $20 billion in potential liabilities at stake.

The case centers on the beverage giant’s transfer pricing methods and how it allocates profits between its U.S. operations and overseas subsidiaries.

The move marks a significant intensification of a conflict that has persisted for years.

By taking the matter to the appellate level, Coca-Cola is challenging the IRS’s interpretation of international tax rules, arguing that the agency’s assessment of its global profit distribution is incorrect.

The outcome could set a precedent for how multinational corporations structure their international tax obligations.

This development adds to a broader landscape of heightened scrutiny on corporate tax practices.