OECD Releases Report on Pillar One – Amount B

The OECD recently released new guidance on Amount B of Pillar One to simplify transfer pricing for taxpayers, but the rules are complicated.

The framework on Amount B provides a simplified approach to establish a fixed return for baseline marketing and distribution activities, known as the Simplified and Streamlined Approach.

The goals of this approach include reducing transfer pricing disputes and compliance costs while providing increased tax certainty for administrations and taxpayers, but they are complicated by the optional implementation and limited scope of this approach.

This OnPoint provides an overview and breakdown of this new guidance to make it easier for tax practitioners to understand, while also providing insight into further guidance that will come out from the OECD.

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