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On 17 July 2023, the OECD released an updated public consultation document on Amount B of Pillar One, which attempts to simplify the transfer pricing of certain baseline wholesale marketing and distribution activities. Comments on the consultation document are due 1 September 2023.

The consultation document outlines the design elements of Amount B and identifies aspects which require further work, including:

  • Ensuring an appropriate balance between quantitative and qualitative approaches in identifying baseline distribution activities;
  • Determining the appropriateness of the pricing framework and its application; and
  • Identifying the criteria to apply Amount B utilising local databases in certain jurisdictions.

The IF plans to approve a final report on Amount B and incorporate key content into the OECD Transfer Pricing Guidelines (TPG) by January 2024. It is important to note that the proposals outlined in the consultation document represent the work of the OECD Secretariat, since the IF has not yet reached consensus on them. Their basic design may be subject to change, unrelated to the consultation process.