Why should taxpayers act on Amount B, now?

August 11, 2023
Amount B

Recently, the OECD released a public consultation document on Amount B under Pillar One.  

Why should taxpayers act on Amount B, now?

  • In the past, the scope of Amount B under Pillar 1 was intrinsically linked to Amount A, which applies exclusively to large businesses.

  • Amount B has recently evolved to be relevant for all businesses, with particular focus on baseline wholesale distribution activities and more specifically a buy-sell distributor, a sales agent or a commissionaire.

  • With Amount B, the OECD aims at introducing steps to simplify and streamline the application of the arm’s length principle to in-scope distributors, including preparation of a pricing matrix per industry grouping.

  • Whether Amount B is implemented as a safe harbor or a prescriptive approach is still to be determined.

Public comments are requested by September 1, 2023. The Inclusive Framework aims to complete its remaining work in time for the final report on Amount B to be incorporated into the OECD Transfer Pricing Guidelines in January 2024.

Read a July 2023 report or listen to the podcast prepared by KPMG that provides initial observations of the public consultation document.

Our Transfer Pricing team is happy to discuss these developments specific to your distribution functions.

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