KPMG report: New Amount B guidance expands on definitions

A KPMG report that discusses the June 2024 Amount B guidance.

Download PDF
June 20, 2024

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

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.

By submitting, you agree that KPMG LLP may process any personal information you provide pursuant to KPMG LLP\'s . Privacy Statement

An error occurred. Please contact customer support.

Job seekers

Visit our careers section or search our jobs database.

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Office locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Headline