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
Going further than the comparability adjustments typically made in economic analyses
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