PLI and Working Capital Adjustments
This PLI is the ratio of operating profit to sales
What is operating margin?
The Stores terminology Amazon uses in its reports
What are "Amazon Stores"
This type of agreement can be obtained from the IRS to determine the appropriate transfer pricing methodology for future transactions
What is an Advance Pricing Agreement (APA)?
This country has recently made OECD standard Master File and Local File beginning on/after April 1, 2023 for Taxpayer with a CbyC reporting obligation (i.e., Group consolidated revenue of EUR 750 million)
What is the UK?
This method evaluates whether the amount charged for certain services is arm's length by reference to the total services costs with no markup
What is Services Cost Method (SCM)?
This PLI is the ratio of gross profit to operating expenses
What is Berry ratio?
The typical accounting standard method used by Amazon
What is US GAAP?
The method that determines if the allocation of combined operating profit among controlled transactions is arm's length based on each participant's contributions
What is the profit split method (PSM)?
As of 2024, this country implemented new transfer pricing regulations aligning more closely with OECD guidelines and emphasizing the arm’s length principal.
What is Brazil?
In transfer pricing, this acronym stands for the five critical functions that must be evaluated to determine the allocation of profits from intangibles
What is DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation)
The PLI range used by Canada for TP documentation purpose
What is single year full range
Amazon acquired this medical company in February 2023
What is "One Medical"
The documentation that includes requirements to select and apply a method in a reasonable manner, maintain sufficient documentation thereof, and promptly provide a documentation to the IRS
What is the "6662(e) documentation"?
Penalizes large companies that have significant outbound payments to foreign related parties
This concept is typically defined as a fixed place of business that gives rise to income in a jurisdiction.
What is a permanent establishment?
The updated IRS guidance for working capital adjustment - the interest rate to be used going forward for calculating comparability adjustments for AR and AP
What is 3-month SOFR plus 140 basis points
The number of Amazon back long reports currently outstanding for FY21
What is “14”?
This method, as outlined in Temp. Treas. Reg. § 1.482-9T(b), evaluates the arm’s length nature of pricing for covered services based solely on the total services cost with no markup.
What is the Services Cost Method (SCM)?
This emerging market has indicated its intention to adopt Amount B
What is Argentina, Brazil, Costa Rica, Mexico, and South Africa? (will accept any of these answers)
Two or more parties sharing expenses and risks to develop a technology/intangible
What is a Cost Sharing Arrangement
The inventory adjustment interest rate APA office uses
What is Moody’s BAA rate
Amazon’s three business segments
What are “North America, International, and AWS”
This advanced transfer pricing term describes a systematic approach to determine the arm's length charge for the use of intangibles within a multinational enterprise under a cost sharing arrangement, focusing on the anticipated benefits each entity is expected to receive
What is the “anticipated benefits test”?
This new development by OECD intent to simplify transfer pricing for routine marketing and distribution activities across different industries, making it easier for businesses to comply with TP rules and tax authorities
what is OECD’s Pillar One Amount B
BEPS Pillar 2 framework minimum tax rate
What is 15%?