The Resource US Tax Court ruled in favour of Amazon US addressing a cost-sharing arrangement and the related transfer of intangible assets

US Tax Court ruled in favour of Amazon US addressing a cost-sharing arrangement and the related transfer of intangible assets

Label
US Tax Court ruled in favour of Amazon US addressing a cost-sharing arrangement and the related transfer of intangible assets
Title
US Tax Court ruled in favour of Amazon US addressing a cost-sharing arrangement and the related transfer of intangible assets
Creator
Subject
Language
eng
Summary
The Amazon Case (Docket No 31197-12, [2017] T.C. No. 8) deals with a commonly used structuring of US multinational enterprises (MNE) to set up a non-US company structure to explore the European or global markets outside the US by way of a transfer of intangibles using a cost-sharing arrangement (CSA). This article deals with the structuring chosen by Amazon, the proposed tax adjustments, and the judgment of the Court in more detail, followed by an analysis of such structuring in the light of the update in Chapter VIII of the OECD Transfer Pricing Guidelines (TPG) 2017 on cost-contribution arrangements (as recommended in the final report on BEPS Action 8)
Citation source
In: TPI - Transfer Pricing International. - Wien. - Vol. 1 (2017), no. 5 ; p. 260-267
http://library.link/vocab/creatorName
  • Storck, A
  • Miladinovic, A
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • OECD Transfer Pricing Guidelines
  • cost sharing arrangement
  • intangibles
  • MNE
  • transfer pricing
  • buy-in payment
  • safe harbour
  • BEPS Project (OECD)
  • case law
Label
US Tax Court ruled in favour of Amazon US addressing a cost-sharing arrangement and the related transfer of intangible assets
Instantiates
Publication
Label
US Tax Court ruled in favour of Amazon US addressing a cost-sharing arrangement and the related transfer of intangible assets
Publication

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