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.