The practical application of several transfer pricing methods involves comparing the profit of an enterprise (or one of its activities) with the profit of independent enterprises considered as “comparable”. The
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Going further than the comparability adjustments typically made in economic analyses
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Amazon: IRS loose again
In the March 23rd, 2017 decision Amazon.com, Inc. v. Commissioner, T.C., No. 31197-12, 148 T.C. No. 8, the US Tax Court concluded that the United States tax authorities had an