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U.S. Federal Appeals Court Holds IRS Must Apply Definition of Intangibles under Prior Regulations in Amazon Transfer Pricing Case

|Approved Changes|United States
United States

On 16 August 2019, the U.S. Court of Appeals for the Ninth Circuit issued its decision (opinion) on a transfer pricing case concerning whether buy-in payments made in 2005 and 2006 by a Luxembourg subsidiary of Amazon under a cost sharing arrangement should include compensation for residual-business assets, such as the value of workforce in place, going concern value, and goodwill.

One of th…

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