Anheuser-Busch InBev Worldwide, the global brewing company behind Budweiser, has filed a lawsuit challenging the Tennessee Department of Revenue’s decision to deny a significant tennessee tax refund claim. This high-stakes dispute, now unfolding in Davidson County Chancery Court, highlights ongoing tensions following the state’s recent overhaul of its franchise tax policy.

Background: Franchise Tax Refund at the Heart of Dispute

According to court documents, Anheuser-Busch InBev (AB InBev), a Delaware-headquartered corporation, seeks more than $1.8 million in franchise tax refund, plus interest. The taxes in question relate to the 2022 and 2023 tax years, during which AB InBev paid nearly $2 million under state franchise tax rules that were subsequently reformed in 2024. The company, which reported no tangible property located within Tennessee, argues that the previous calculation method resulted in an excessive tax burden.

Tennessee Tax Reform Spurs Legal Action

The lawsuit arrives in the wake of the 2024 Tennessee tax reform, which eliminated a controversial avenue for calculating state franchise taxes. The reform allows certain businesses to retroactively seek refunds for taxes paid under the former system, provided they submitted claims within a specified window. AB InBev’s tax refund claim was filed in August 2025, shortly after the new law was enacted. The company’s claim remained undecided for over six months, an administrative period after which Tennessee law deems the application denied—triggering the current ab inbev lawsuit.

Dispute Over Tax Calculation and Apportionment

Central to the controversy is the tax calculation dispute involving the state’s approach to net worth, property, and the interstate business apportionment formula. AB InBev alleges that the Tennessee Department of Revenue improperly applied these factors, resulting in an unfair assessment that violated both state and federal law. This aspect draws broader attention from other interstate companies with similar operations and tax configurations in the region.

Legal Claims and Refund Denial

In its tax refund lawsuit, AB InBev asks the court to direct the state to correct its calculations, process the franchise tax refund as required under the new legal framework, and compensate for any fees and damages incurred. The company also asserts that the state’s failure to respond within the six-month window amounts to wrongful tax refund denial.

Response from State Department of Revenue

To date, neither the Tennessee Department of Revenue nor company representatives have issued public statements about the legal action. The state department of revenue is one of several agencies now managing an influx of refund claims related to tennessee tax reform and franchise tax changes. For many in Tennessee, the proceedings are seen as a test case that could influence future interpretations of tax refund claims and state franchise taxes for businesses without a major physical presence in the state.

Wider Implications for Tennessee’s Business Community

The outcome of this debate holds significance for other companies considering similar challenges to Tennessee’s tax policies. As the state processes numerous franchise tax refund requests following broad legislative changes, the AB InBev dispute over tax refund denial and calculation could set an important precedent for how interstate business apportionment and tax reform measures are interpreted going forward.

Next Steps in the Tax Refund Lawsuit

Court proceedings in the region are expected to clarify Tennessee’s obligations regarding tax refund claim submissions made after the 2024 franchise tax reform. Until a final decision emerges, businesses across Tennessee—and their legal and financial teams—are closely monitoring developments around this tennessee tax refund case for any broader regulatory or financial ripple effects.