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In brief

Amount B was introduced as a “fixed return” on “baseline marketing and distribution activities” in the October 2020 Blueprint of Pillar One, and was seen as a critical component of the Pillar One deal. 

Following the long-awaited release of the consultation document on 8 December 2022 (“December 2022 Consultation Document“) and subsequent public commentary received, the OECD/G20 Inclusive Framework on BEPS (“IF“) published a consultation document on Amount B on 17 July 2023 (“July 2023 Consultation Document“), creating renewed momentum and putting Amount B back into the international tax spotlight. 

The OECD has requested input from stakeholders on a number of remaining technical points, with comments to be received no later than 1 September 2023.

Following the public consultation, the OECD intends to finalize the guidance on Amount B and publish it as an addition to the OECD Transfer Pricing Guidelines (“OECD Guidelines“) in January 2024.

Click here to read the full alert.


Vladimir Zivkovic is a Counsel in Baker McKenzie Amsterdam’s Transfer Pricing team. He has 10+ years of experience in transfer pricing and value chain analysis. Vladimir started his career in Canada in 2008 and relocated to the Netherlands in 2011.


Imke Gerdes is a partner in Baker McKenzie's New York office, co-chair of the New York and Miami Inclusion and Diversity Committee and a member of the Firm's North America Transfer Pricing Steering Committee. Before joining the New York office, she was a partner in the Firm's Vienna office. Imke is admitted to the German Bar, the New York Bar and she is admitted as tax advisor ("Steuerberater") to the Austrian Chamber for Tax Advisors.


Mr. Sprague was one of five business representatives selected by the OECD to participate in the OECD Technical Advisory Group ("TAG") on Tax Treaty Characterisation Issues Arising from E-Commerce, and was elected chair of the business representatives on the TAG. He also was appointed by the OECD to serve as the business co-chair on the Technical Advisory Group on Monitoring the Application of Existing Treaty Norms for the Taxation of Business Profits. He was the Co-General Reporter for the subject Taxation of Income Derived from Electronic Commerce for the International Fiscal Association 2001 Congress, and is a co-author of BNA Tax Management Portfolio No. 555, Federal Taxation of Software and E-Commerce. He is the General Reporter for the subject Big Data and Tax – domestic and international taxation of data driven business for the International Fiscal Association 2021 Congress. He also is a regular contributor to the Tax Management International Journal's Leading Practitioner Commentary.


Alejandro Zavalais is a Legal Director in Baker McKenzie’s Amsterdam office. Prior to joining the European transfer pricing team in 2015, he was part of the Firm's Mexican transfer pricing and valuation group, working for five years with multinational companies operating in Latin American countries and the US.

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