Elke Stetter-Gassan

This report focuses on the

• analysis of valuation techniques applied in the context of transfer pricing,
• practical application of these techniques in EU Member States and trade partners,
• identification of potential legislative measures, and
• capacity building approaches for tax administrations.

The report wraps up with reflections of possible policy actions that could be helpful to tax administrations and taxpayers regarding the valuation of intangibles for transfer pricing purposes in the EU.

Please follow the link: https://publications.europa.eu/en/publication-detail/-/publication/e7dbd290-c682-11e6-a6db-01aa75ed71a1

Roberto H Castro recently published a fascinating note on a US Tax Court Decision on Valuing Intangible Assets for Transfer Pricing Purposes based on Amazon.com, Inc. and Subsidiaries vs. Commissioner, 148 T.C. 8 (March 23, 2017). It is worthwhile to read the article and the judgment which covers more than 200 pages.

Amazon entered into a cost sharing arrangement (CSA) with its Luxembourg subsidiary in 2005. Within this CSA, Amazon.com granted its Luxembourg subsidiary the right to use certain pre-existing intangible assets in Europe. This right includes the intangibles required to operate Amazon.com’s European website business.

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