Report on Amount B of Pillar One: Promises Kept?

Amount B is intended to provide relief from compliance burdens for taxpayers, enabling tax administrations to allocate resources toward riskier and more complex transactions, with a special focus on the needs of low-capacity jurisdictions. The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (“IF”) sought to accomplish these goals through creation of a consensus around a simplified and streamlined approach (the “Approach”) for the transfer pricing of baseline wholesale marketing and distribution activities.

On February 19, 2024, the IF released a report on Amount B of Pillar One (the “Report”) which will be incorporated into the OECD Transfer Pricing ...