As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy and following the agreed Outcome Statement, the OECD is seeking public comments on Amount B under Pillar One.

Amount B provides for 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 low-capacity countries.

• Access the public consultation document (PDF)

Interested parties are invited to submit their comments* on this discussion draft with a particular focus on the issues identified above by 1 September 2023. Due to the high volume of anticipated submissions, stakeholders are encouraged to send in their comments in the form of a questionnaire. If this is not possible, comments should be sent by e-mail to TransferPricing@oecd.org in Word format. Comments in excess of ten pages should attach an executive summary limited to two pages. Comments should be addressed to the Tax Treaties, Transfer Pricing and Financial Transactions Division, OECD/CTPA.

• Download the summary for an overview of the main features of the Amount B design (also available in French)

Given that open issues remain, the proposals included in this consultation document do not represent the consensus views of the Inclusive Framework on BEPS, the Committee on Fiscal Affairs or their subsidiary bodies.

*Please note that all written comments received will be made publicly available. Comments submitted in the name of a collective “grouping” or “coalition”, or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting.

Published 20 September 2023

The OECD is grateful to the commentators for their input and now publishes the public comments received.

• Download the comments (Zip file, 21MB - Please open from a desktop computer) - Updated 26 September 2023 with additional comments

For more information or inquiries, please contact Manuel De Los Santos, Head of the Transfer Pricing Unit or the Communications Office at the OECD Centre for Tax Policy and Administration.