KPMG report: New Amount B guidance expands on definitions
A KPMG report that discusses the June 2024 Amount B guidance.
The OECD/G20 Inclusive Framework (IF) on Base Erosion and Profit Shifting (BEPS) on June 17, 2024, published additional guidance 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 provides little additional clarity on implementation, but it does expand on three definitional issues under the February 2024 guidance on Amount B (read TaxNewsFlash):
- “Low-capacity jurisdictions” that would benefit from having Amount B respected by counterparty countries
- “Qualifying jurisdictions” that would benefit from favorable (from the tax authority’s perspective) treatment under the operating expense cross-check mechanism
- “Qualifying jurisdictions” that would benefit from the favorable (again for the tax authority) data availability mechanism
Read a June 2024 report* prepared by KPMG LLP that discusses the June 2024 Amount B guidance
* Reproduced with permission from Tax Management International Journal, 6/20/2024. Copyright @ 2024 by Bloomberg Industry Group, Inc. (800-372-1033) http://www.bloombergindustry.com