Beyond State Aid: A Transfer Pricing Analysis for the Amazon Case

This study focuses on an analysis of the recent Amazon case from a purely transfer pricing perspective. The analysis is hence based on a four-step procedure, namely, accurate delineation of the transaction, its recognition, selection and application of the most appropriate transfer pricing method (MAM). As such, the perspective described in this text consciously does not address the state aid framework. This study is structured as follows: after the introduction in section 1., section 2. details the facts of the case, section 3. analyses the transfer pricing implications and section 4. sets forth conclusions.