The OECD on 11 October 2023 released a package of guidance in relation to Amount A of Pillar One: the text of a consensus-based Multilateral Convention (MLC) and accompanying explanatory statement, an Understanding on the Application of Certainty for Amount A of Pillar One (UAC), and an update to the economic impact assessment of Pillar One. Notably absent from the package is any further guidance on Amount B (i.e., transfer pricing for routine distribution and marketing transactions), which the Inclusive Framework (IF) continues to work on, post-consultation, to provide final guidance by the early part of 2024.
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