Today, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) is publishing a Model Competent Authority Agreement (MCAA) to facilitate the implementation of its political commitment on Amount B of Pillar One. This practical tool is designed to be particularly beneficial for jurisdictions with limited resources and data availability.

At the beginning of this year, the Inclusive Framework released a report on Amount B of Pillar One. This report provides a simplified and streamlined pricing framework for baseline marketing and distribution activities that is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike.

The implementation of Amount B is supported by the political commitment from all Inclusive Framework members to take all reasonable steps to relieve potential double taxation that may arise from the application of the simplified and streamlined approach by a covered jurisdiction where there is a bilateral tax treaty in effect.

Additional guidance on Amount B – including the definition of covered jurisdiction for the Inclusive Framework political commitment on Amount B – was published in June 2024, allowing jurisdictions to begin with implementation.

Further work on the Pillar One package, including the Amount B framework, is ongoing as indicated in the Statement by the Co-Chairs of the Inclusive Framework on 30 May 2024.

For further information, journalists are invited to contact Manal Corwin (+33 1 45 24 18 80), Director of the OECD Centre for Tax Policy and Administration, or ctp.communications@oecd.org.