Monday, 12 June 2017

Tax Court in Amazon rejects IRS’s proposed application of income method for pricing cost-sharing buy-in payments

In an important transfer pricing opinion published on March 23, 2017, the U.S. Tax Court in, Inc. v. Commissioner rejected the IRS’s preferred approach to pricing cost-sharing buy-in payments as inconsistent with the arm’s length standard, employing reasoning that has implications for related-party transfers of intangible property in general.

The opinion represents the latest in a series of court decisions rejecting the IRS’s interpretation and application of the arm’s length standard, especially with respect to transfers of intangible property between related parties.

Source & more info: PwC