The OECD on 24 February 2025, announced the release of a consolidated report on Amount B of Pillar One of the two-pillar solution to address the tax challenges arising from the digitalisation and globalisation of the economy.
The report marks the latest step in the development of Amount B, a simplified and streamlined approach to the application of the arm’s length principle to in-country baseline marketing and distribution activities, with a particular focus on the needs of “qualifying jurisdictions,” defined as jurisdictions that are classified by the World Bank Group as low income, lower-middle income, and upper-middle income.
The consolidated report incorporates materials on Amount B published by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting from February 2024 through December 2024. According to the report, “[t]he content of the original publications has not been amended or modified; the Consolidated Report on Amount B simply replicates the original content for ease of reference.”
The 68-page consolidated report includes three principal elements of guidance on Amount B:
Laurie Dicker
BDO in United States
The report marks the latest step in the development of Amount B, a simplified and streamlined approach to the application of the arm’s length principle to in-country baseline marketing and distribution activities, with a particular focus on the needs of “qualifying jurisdictions,” defined as jurisdictions that are classified by the World Bank Group as low income, lower-middle income, and upper-middle income.
The consolidated report incorporates materials on Amount B published by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting from February 2024 through December 2024. According to the report, “[t]he content of the original publications has not been amended or modified; the Consolidated Report on Amount B simply replicates the original content for ease of reference.”
The 68-page consolidated report includes three principal elements of guidance on Amount B:
- The original report on Amount B published on 19 February 2024;
- Statements on the definitions of “qualifying jurisdiction” within the meaning of sections 5.2 and 5.3 of the February 2024 guidance and “covered jurisdiction” for purposes of the Inclusive Framework political commitment on Amount B published on 17 June 2024; and
- A Model Competent Authority Agreement (MCAA) on the application of the simplified and streamlined approach designed to facilitate the implementation of that political commitment, originally published on 26 September 2024.
Laurie Dicker
BDO in United States