KPMG report: Public consultation on Amount B under Pillar One, initial observations and analysis

Initial observations and analysis of the public consultation document

Initial observations and analysis of the public consultation document

The Organisation for Economic Cooperation and Development (OECD) on 8 December 2022 released a public consultation document on Amount B under Pillar One [PDF 1 MB].  The document builds on the commitment the OECD/G20 Inclusive Framework (IF) on base erosion and profit shifting (BEPS) reached in October 2021 to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities.

Amount B is designed to address the challenges low-capacity jurisdictions face applying transfer pricing rules, help re-stabilize the international tax system, and reduce the compliance costs businesses incur due to transfer pricing disputes. The public consultation document provides the first detailed insights into how the IF considers Amount B could operate, since the Pillar One Blueprint was published more than two years ago.

Read a December 2022 report [PDF 142 KB] prepared by KPMG tax professionals that provides initial observations and analysis of the public consultation document


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