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.
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