International - Amazon Goldcrest Project and the Relevance of Comparability Analysis under the Arm’s Length Principle
- R.S. Avi-Yonah; A. (Andrea) Musselli
- International Transfer Pricing Journal, 2019 (Volume 26), No 3
- 15 May 2019
The arm’s length principle, which has long been the guiding rule in the area of transfer pricing, in recent years is increasingly challenged. One of the focus points of discussion is the comparability analysis of intra-group and independent transactions. Especially intangibles do not lend themselves to such analysis, because they are unique in a way that does not match with existent market equilibria. The analysis of the Amazon case in this article reflects this argument.