US Tax Court rules in Amazon’s favor; Rejects ‘perpetual life’ assumption for website technology, marketing intangibles

Mar 27,2017

US Tax Court rules in favor of Amazon US in respect of TP adjustments amounting to $8.3mn and $225mn for 2005 and 2006 made by IRS on account of transfer of intangible assets required to operate Amazon’s European website business to its Luxembourg subsidiary, follows Veritas Software ruling; Rejects Discounting Cash-Flow (DCF) methodology adopted by IRS for determining arm’s length “buy-in payment” of pre-existing intangibles as it...


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