Coca-Cola has been evading taxes through accounting practices that allow the company to shunt profits overseas, a tax court judge has ruled.

The Internal Revenue Service notified Coca-Cola in 2015 that it owed more than $3.3 billion in corporate taxes for 2007 through 2009. The IRS accused Coca-Cola of packing profits into subsidiaries in Egypt, Brazil, Ireland and other countries that mostly make soft-drink syrup.

The ruling from U.S. Tax Court Judge Albert Lauber adopted much of the IRS’s reasoning, noting that the subsidiaries in question showed profits far in excess of Coca-Cola as a whole.

“Why are the [subsidiaries], engaged as they are in routine contract manufacturing, the most profitable food and beverage companies in the world?” Lauber wrote in his opinion.

Lauber did not set a dollar amount for Coca-Cola to pay in back taxes. Coca-Cola expressed disappointment in the ruling and vowed to appeal.