The OECD/G20 Inclusive Framework on BEPS (IF), on 19 February 2024, released a report (Report) (and reader’s guide ) on Amount B of Pillar One, now referred to as the ‘simplified and streamlined approach.’ The Report introduces two elective options for the transfer pricing of certain baseline wholesale marketing and distribution activities. The Report follows the OECD’s previous public consultations in July 2023 and December 2022 (July 2023 Consultation Document and December 2022 Consultation Document, respectively).
The content from the Report has been incorporated as an Annex to Chapter IV of the OECD Transfer Pricing Guidelines (TPG). The IF is developing additional guidance on Amount B with a view to concluding this work by 31 March 2024. Any additions (namely, an optional qualitative scoping criterion) will be incorporated into the TPG at that time. The list of jurisdictions that opt into Amount B within their jurisdictions will be made available on the OECD website.
We focus in particular in this Bulletin on changes from the July 2023 Consultation Document.