The OECD has released further tools to enable the implementation of a simplified and streamlined approach to transfer pricing under Amount B. These tools include a set of fact sheets that provide a high-level overview of the mechanics of Amount B and a Pricing Automation Tool to facilitate the computation of the Amount B return for an in-scope tested party with the requirement of minimum data inputs
Pricing Tool
As part of the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy agreed by the OECD/G20 Inclusive Framework on BEPS in October 2021, Amount B provides for a simplified and streamlined approach to the application of the arm’s length principle to in-country baseline marketing and distribution activities, with a particular focus on the needs of low-capacity jurisdictions.
Source OECD
Fact Sheets
The simplified and streamlined approach (Amount B) provides a framework to simplify the application of the arm’s length principle to baseline marketing and distribution activities. It is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike.
Jurisdictions can choose to adopt Amount B for in scope transactions for fiscal years commencing on or after 1 January 2025.
Source OECD
