Unexpected outcomes and potential challenges that businesses may need to consider
The OECD/G20 Inclusive Framework (IF) on Base Erosion and Profit Shifting (BEPS) in February 2024 released a report on Amount B, the OECD’s initiative to simplify and streamline the application of the arm’s length principle to baseline marketing and distribution activities. The guidance gives jurisdictions the option to apply the Amount B approach from January 2025, either as a taxpayer safe harbor or as a mandatory rule.
Read a June 2024 report* prepared by KPMG LLP that highlights unexpected outcomes and potential challenges that businesses may need to consider in their response to Amount B.