In Coca-Cola Co. & Subsidiaries v. Commr., the taxpayer learned an important lesson for multinational groups using a residual profit split method to determine intercompany transfer prices. The factual underpinning of a residual profit split is critical to method selection, best method analysis, and selection of a reliable split metric when applying the method. In the case, the taxpayer relied on a favorable resolution of transfer pricing issues in an examination of earlier years and failed to confirm the continued existence of favorable facts. Michael Peggs explains all. Resolution of an examination does not provide the same certainty as an advance pricing agreement.