Latest Developments On Pillar One's Amounts A And B And The Dutch Position

We summarise the latest developments and explain the next steps regarding Pillar One's Amount A and Amount B. We also include the Dutch position on this matter, as recently expressed by the State Secretary of Finance in a letter sent to the Dutch Parliament.

Overview

Pillar One's Amount A seeks to create a new taxing right for market jurisdictions, which will be independent of the physical presence requirement and determined using a formulaic approach. In addition, Pillar One's Amount B aims to introduce simplifications to the transfer pricing approach to "baseline marketing and distribution activities" (BMDA). Pillar One also includes mandatory and binding dispute prevention and resolution mechanisms to mitigate the risk of multiple taxation.