The Norwegian Tax Administration published a release on 31 March 2025 outlining the implementation of Amount B, which aims to simplify transfer pricing rules under Pillar One.

Norway’s Ministry of Finance has decided that amount B shall not be applied in Norway now. This means that when determining tax, the pricing of transactions between related parties must be based on the guidelines on the OECD Transfer Pricing Guidelines (TPG) under section 13-1 of the Taxation Act.  Furthermore, this means that in an amicable settlement procedure following a tax treaty, one must base one’s position about the pricing of a transaction on the guidelines in the TPG in general.

The G20/Inclusive Framework (IF) has agreed that member states shall accept Amount B as the basis for pricing qualifying transactions when specific jurisdictions, in their tax assessment, allow Amount B to be used as the basis for pricing such qualifying transactions. The agreement applies only to transactions between independent legal entities, not to relationships between head office and branch/permanent establishment.

This means that the tax assessment relating to these transactions may be based on Amount B when the conditions for applying Amount B are met and the pricing matrix is ​​correctly applied. However, the Tax Administration may assess whether the conditions are met and that the pricing matrix is ​​correctly applied. If the conditions are not met, the transaction is evaluated according to the main guidelines in the TPG.

The agreement applies initially from 1 January 2025 to 31 December 2029.

The OECD/G20 Inclusive Framework agreed in February 2024 on a framework for pricing intragroup transactions related to marketing and distribution activities. The framework was published in the report Pillar One—Amount B on 19 February 2024. The report’s section on Special considerations for baseline distribution activities is incorporated into the OECD Transfer Pricing Guidelines as a new addition to Chapter IV. Jurisdictions may choose to implement the framework for financial years beginning after 31 December 2024.

Amount B offers a simplified approach for pricing controlled transactions involving basic marketing and distribution activities. Countries can apply Amount B to transactions of distributors, sales agents, and brokers operating in their country for accounting periods starting on or after 1 January 2025.

As part of the IF two-pillar project, as part of Pillar One, work has been underway to simplify the application of the arm’s length principle when pricing intra-group transactions related to marketing and distribution functions.