据外媒报道，SEC近期就一些会计问题对亚马逊进行了调查，其中包括新收入准则下收入确认有关问题。
在与SEC的反复交涉中，亚马逊拒绝提供其Prime会员收入有关信息。与此相呼应的是，今年早些时候谷歌母公司Alphabet同样拒绝了SEC发出的根据新收入准则披露YouTube收入的请求。
SEC在8月时曾向亚马逊发出问询函，要求亚马逊就以下四个问题进行答复和披露：
1. 亚马逊Prime会员贡献的净销售额占比；
We note from statements in your Current Report on Form 8-K filed on April 18, 2018that you have exceeded 100 million paid Prime members globally and that you shippedmore than five billion items in 2017 with Prime worldwide. In future periodic reports,please disclose the percentage of net sales attributable to sales to Prime members versussales to non-Prime members.
2. 由SageMaker（机器学习服务）等新服务贡献的净销售额增长；
We note that AWS Sales increased 43% in 2017 as a result of increased customer usage,partially offset by pricing changes. We further note statements from your Current Reporton Form 8-K filed on April 18, 2018 that active users increased by more than 250%“spurred by the broad adoption of Amazon SageMaker.” To the extent increases in netsales are attributable to the adoption of new services, such as Amazon SageMaker, pleasedisclose as much in future periodic reports. Please refer to Item 303 of Regulation S-K.
3. 亚马逊如何确定其在销售数字媒体内容时是作为委托人还是代理人（是以总额还是净额为基础列报销售情况）；
We note your disclosure on page 9 that sales from certain digital media content ispresented on a net basis. We also note your disclosure on page 19 that digital mediacontent is presented on a gross basis. Please provide us with your analysis of how youdetermined whether you are acting as a principal or as an agent in thesearrangements. Please also revise your disclosures as appropriate.
4. 亚马逊是在单一时点还是在提供服务期间持续确认云服务、广告服务及其第三方销售服务的收入。
We note your disclosure that revenue related to your third-party seller services, AWSarrangements and advertising services is recognized as the services are rendered. Pleasetell us and revise to clarify if revenue from these services is recognized over time or at apoint in time. Please also clarify your methods used to measure progress, if applicable,and why the methods reflect a faithful depiction of the transfer of the services.
亚马逊直接拒绝回答第一个问题，认为“销售是否与Prime会员相关，不能反映净销售额的本质，也无法就此方面提供有用信息。Prime会员情况与财务报告系统无关。”
We respectfully do not believe that net sales attributable to Prime members versus sales to non-Prime members is meaningful or useful information. As an example, slower growth or a decline in net sales, including those attributable to Prime members, may reflect increased customer purchases of products from third-party sellers, since the same product sold through our website for the same price can produce different margins (and percent of net sales results) depending on whether it is sold by Amazon or by a third-party seller. Prime membership is primarily a service designed to enhance overall customer experience and convenience, promote customer loyalty, and provide customers access to the many products and services that are available through our websites, mobile apps, Alexa, and our physical stores, which are all part of our omnichannel distribution system. As with Alexa, our Kindle e-readers, and other offerings and services, Prime is only one element that supports our focus on selling a wide range of products and services. As a result, whether sales are associated with Prime membership does not reflect on or provide useful information about the nature of our net sales and does not reflect how management views the business.
There are a number of additional factors that limit the significance or usefulness of information on the extent to which net sales are attributable to Prime members. First, changes in the percentage of net sales attributable to Prime members could reflect many varying factors disconnected from and unrelated to the Prime program. As an example, this percentage would be impacted by net sales from AWS and other net sales that are not associated with our Prime program. In addition, utilization of Prime member benefits is not necessarily associated with activity in a customer’s account. For example, a Prime member may purchase an item that is not “Prime-eligible” (i.e., for which Prime shipping benefits are not available), or may utilize a Prime benefit that does not result in us recording revenue (such as free access to certain digital content or ad-free viewing on Twitch). In other situations, the correlation between a Prime membership and our net sales may be difficult to assess, such as when we provide Prime members early access to certain deals. Finally, the ability of a customer’s account to shift into and out of Prime status also affects both the ability to define and the relevance of Prime member net sales. For example, we provide monthly prime memberships, as well as promotional and trial memberships, and an account holder can choose whether to become a Prime member at any time, and likewise can cancel membership on several days’ notice or allow Prime membership to lapse during the year.
For the foregoing reasons, management does not track the percentage of net sales that are attributable to Prime members and, therefore, Prime membership status is not tied into our financial reporting systems. As we further develop our omnichannel distribution system, it may become more difficult to associate net sales with a Prime membership. Accordingly, we believe that the net sales information on our groups of similar products and services we now voluntarily report on a quarterly basis provides the most useful insight into the nature and sources of our net sales. In this disclosure, our subscription services category largely relates to Prime memberships.
亚马逊对于第四个问题的答复也被SEC认为是语焉不详，仍未说明相关服务的收入确认情况。
随着SEC越来越关注互联网企业和数字经济新业态下新收入准则的应用，是否会有更多数字巨头紧跟亚马逊的脚步，拒绝披露收入相关信息呢？让我们拭目以待。
消费者通过付费成为亚马逊Prime会员，可享受免运费、免费使用数字产品内容库等优惠待遇。与可交付成果相关的收入，将根据服务的预计交付额在会员的有效期间内摊销。亚马逊Prime会员费将在商品销售和服务销售之间按比例分配。提供Prime会员优惠的成本将被确认为销售成本。
根据亚马逊12月3日最新发布的新闻稿，亚马逊目前已在全球17个国家提供Prime会员服务。去年，全球Prime会员订购了超过20亿件“闪电达”商品。（闪电达，即一天内交货）
据亚马逊2017年度财报披露，FASB发布的新收入准则和新修订的收入确认指南给公司带来的影响主要包括以下几方面业务的收入确认：
失效礼品卡：将在预计的顾客消费期间内（一般为九个月）确认估计的未消费礼品卡收入，而不是等到礼品卡到期失效或顾客消费可能性极低时（通常是自发行之日起两年）再确认收入。
通过零售商销售的Kindle等亚马逊品牌电子设备：在电子设备销售给零售商而不是最终客户时确认销售收入。
Prime会员：Prime会员资格目前被认为是包括商品和服务等多项履约义务的安排。Prime会员之后将被视为在会员期间按比例确认的单项履约义务，并将被归类为服务销售。
广告服务：部分广告服务将确认为收入，而不是冲减销售成本。
Amazon
Revenue Recognition
Accounting Policy
Amazon.com recognizes revenue from product sales or services rendered when the following four criteria are met: persuasive evidence of an arrangement exists, delivery has occurred or service has been rendered, the selling price is fixed or determinable, and collectability is reasonably assured.
Revenue arrangements with multiple deliverables are divided into separate units and revenue is allocated using estimated selling prices if Amazon.com does not have vendor-specific objective evidence or third-party evidence of the selling prices of the deliverables. Amazon.com allocates the arrangement price to each of the elements based on the relative selling prices of each element. Estimated selling prices are management's best estimates of the prices that Amazon.com would charge the customers if Amazon.com was to sell the standalone elements separately and include considerations of customer demand, prices charged by Amazon.com and others for similar deliverables, and the price if largely based on the cost of producing the product or service.
Sales of certain of Amazon.com's digital devices are considered arrangements with multiple deliverables, consisting of the device, undelivered software upgrades and/or undelivered non-software services such as cloud services. The revenue allocated to the device, which is the substantial portion of the total sale price, and related costs are generally recognized upon delivery. Revenue related to undelivered software upgrades and/or undelivered non-software services is deferred and recognized generally on a straight-line basis over the estimated period the software upgrades and non-software services are expected to be provided for each of these devices.
Sales of Amazon Prime memberships are also considered arrangements with multiple deliverables, including shipping benefits, Prime Video, Prime Music, Prime Photos, and access to the Kindle Owners' Lending Library. The revenue related to the deliverables is amortized over the life of the membership based on the estimated delivery of services. Amazon Prime membership fees are allocated between product sales and service sales. Costs to deliver Amazon Prime benefits are recognized as cost of sales as incurred. As Amazon.com adds more benefits to the Prime membership, Amazon.com updates the method of determining the estimated selling prices of each element as well as the allocation of Prime membership fees.
Amazon.com evaluates whether it is appropriate to record the gross amount of product sales and related costs or the net amount earned as commissions. Generally, when Amazon.com is primarily obligated in a transaction, is subject to inventory risk, has latitude in establishing prices and selecting suppliers, or has several but not all of these indicators, revenue is recorded at the gross sale price. Amazon.com generally records the net amounts as commissions earned if Amazon.com is not primarily obligated and does not have latitude in establishing prices. Such amounts earned are determined using fixed fees, a percentage of seller revenues, per-unit activity fees, or some combination thereof.
Product sales represent revenue from the sale of products and related shipping fees and digital media content where Amazon.com records revenue gross. Product sales and shipping revenues, net of promotional discounts, rebates, and return allowances, are recorded when the products are shipped and title passes to customers. Retail sales to customers are made pursuant to a sales contract that provides for transfer of both title and risk of loss upon Amazon.com's delivery to the carrier or the customer. Amazon's electronic devices sold through retailers are recognized at the point of sale to consumers.
Service sales represent third-party seller fees earned (including commissions) and related shipping fees, AWS sales, certain digital content subscriptions, certain advertising services, and Amazon.com's co-branded credit card agreements. Service sales, net of promotional discounts and return allowances, are recognized when service has been rendered.
Return allowances, which reduce revenue and cost of sales, are estimated using historical experience. Allowance for returns was $153 million, $156 million, and $62 million as of December 31, 2015, 2016, and 2017. Additions to the allowance were $1.3 billion, $1.5 billion, and $1.8 billion, and deductions to the allowance were $1.3 billion, $1.5 billion, and $1.9 billion in 2015, 2016, and 2017. Revenue from product sales and services rendered is recorded net of sales and consumption taxes. Additionally, Amazon.com periodically provides incentive offers to the customers to encourage purchases. Such offers include current discount offers, such as percentage discounts off current purchases, inducement offers, such as offers for future discounts subject to a minimum current purchase, and other similar offers. Current discount offers, when accepted by Amazon.com's customers, are treated as a reduction to the purchase price of the related transaction, while inducement offers, when accepted by the customers, are treated as a reduction to purchase price based on estimated future redemption rates. Redemption rates are estimated using Amazon.com's historical experience for similar inducement offers. Current discount offers and inducement offers are presented as a net amount in 'Total net sales.'
Source: 10-K (filing date: 2018-02-02).
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