On 29 September 2017, the Internal Revenue Service filed an appeal against March Tax Court ruling concerning Amazon’s cost-sharing agreement buy-in payment. The case is important because it is expected to provide fundamental guidance on the arm’s length pricing of transfers of intangibles.

Amazon.com Inc on March 23 won a US Tax Court case, fending off IRS transfer pricing adjustments relating to a cost-sharing agreement (CSA) buy-in payment. The transfer pricing adjustments would have increased the online retailer’s taxable income by more than $1.5 billion in 2005 and 2006.