The OECD published additional guidance on key definitions related to Amount B.
The Organisation for Economic Cooperation and Development (OECD) on June 17, 2024, published additional guidance on key definitions related to 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 further details on the implementation of the approach that were omitted from the Amount B report published by the OECD in February 2024. Read TaxNewsFlash. The most important development is that five emerging markets—Argentina, Brazil, Costa Rica, Mexico, and South Africa—have indicated their intention to adopt Amount B.
The OECD has noted that work on an Amount B framework (i.e., a political agreement on which jurisdictions will implement Amount B) remains ongoing as part of the broader work on the Pillar One package. Pending the finalization and implementation of any such agreement, Amount B remains optional for jurisdictions.
Read a June 2024 report prepared by KPMG LLP that provides initial observations and analysis on the Amount B guidance.