BDO Transfer Pricing News

Introduction

After years of debate and negotiation, implementation of the Organisation for Economic Cooperation and Development’s (OECD’s) Pillar One, Amount B took a major step forward recently with the IRS’s release of guidance on the application of the “Simplified and Streamlined Approach.” A day later, the OECD released a pricing tool and fact sheets to facilitate the understanding and operation of the new approach. 

The Netherlands also weighed in on the issue recently, issuing a decree whereby it committed to accept the outcome of the application of Amount B by covered jurisdictions with which it has concluded a bilateral tax treaty, but declined to introduce Amount B for Dutch taxpayers performing baseline marketing and distribution activities.

We also include a report from Spain, where the tax authorities have expressed general support for the implementation of Amount B, but have yet to announce whether they will respect the decision of Inclusive Framework jurisdictions that decide to make application of Amount B mandatory.

Not everything in this issue is about Amount B – we also include an update from Australia on the progress through the legislative process of their public country-by-country (CbC) reporting bill, and a report on the recent TP Minds Australia conference, which highlighted that the transfer pricing landscape continues to evolve both in Australia and across the world.