OECD Invites Public Input On Amount B Under Pillar One Relating To The Simplification Of Transfer Pricing Rules

Amount B provides for a simplified and streamlined approach to the application of the arm's lenght principle to in-country baseline marketing and distribution activities, with a particular focus on the needs of low-capacity countries.

The public consultation document released on 17/07/2023 outlines the design elements of Amount B and is released in order to obtain inputs from stakeholders on the technical aspects of Amount B. As highlighted in the Outcome Statement, further work will be undertaken on particular aspects; such as ensuring an appropriate balance between a quantitative and qualitative approach in identifying baseline distribution activities as well as the appropriateness of the pricing framework, including in light of the final agreement on scope; the application of the framework to the wholesale distribution of digital goods; country uplifts within geographic markets; and the criteria to apply Amount B utilising a local database in certain