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ARTICLE · 10 MAY 2021

OECD's Pillar One Blueprint: Amount B

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Amount B aims to standardize the remuneration of related party distributors that perform baseline marketing and distribution activities in a manner that is aligned with the arm's length principle.

United StatesTax
Scott Stewart
Scott Stewart
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Amount B aims to standardize the remuneration of related party distributors that perform baseline marketing and distribution activities in a manner that is aligned with the arm's length principle. Its purpose is two-fold: First, Amount B is intended to simplify the administration of transfer pricing rules for tax administrations and reduce compliance costs for taxpayers. Second, Amount B is intended to enhance tax certainty and reduce controversy between tax administrations and taxpayers.

Pillar One assumes that distribution and marketing activities would be identified as in-scope based on a narrow scope of activities, set by reference to a defined "positive list" and "negative list" of activities that should and should not be performed to be considered in scope. Quantitative indicators would then be applied to further support and validate the identification of in-scope distributors. It is anticipated that amount B could be based on return on sales, with

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