OECD: Public consultation document on Amount B under Pillar One following outcome statement on BEPS 2.0

Comments requested by 1 September 2023

Public consultation document following outcome statement on BEPS 2.0

The Organisation for Economic Cooperation and Development (OECD) today issued a public consultation document on Amount B under Pillar One [PDF 752 KB]—part of the ongoing work of the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) in implementing the two-pillar solution to address the tax challenges arising from the digitalisation of the economy—following release of the agreed outcome statement on BEPS 2.0. Read TaxNewsFlash

As explained by today’s OECD release,

  • 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 countries.
  • The public consultation document released today outlines the design elements of Amount B and is released in order to obtain input from stakeholders on the technical aspects of Amount B. The OECD also prepared a summary [PDF 264 KB] of the main features of the Amount B design.
  • Given that open issues remain, the proposals included in this consultation document do not represent the consensus views of the Inclusive Framework on BEPS, the Committee on Fiscal Affairs or their subsidiary bodies.
  • As highlighted in the outcome statement on BEPS 2.0 released last week, further work will be undertaken on the following aspects:
    • Ensuring an appropriate balance between a quantitative and qualitative approach in identifying baseline distribution activities
    • The appropriateness of:
      • The pricing framework, including in light of the final agreement on scope
      • The application of the framework to the wholesale distribution of digital goods
      • Country uplifts within geographic markets
      • The criteria to apply Amount B utilizing a local database in certain jurisdictions

Comments are requested by 1 September 2023, and instructions for submitting comments can be found in the consultation document. 



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