France will not apply the OECD’s simplified transfer pricing method, Amount B, to domestic transactions from 2025, but will recognise its outcomes in treaty partner jurisdictions to avoid double taxation.
Regfollower Desk
France’s tax authority has announced that it will not implement Amount B under Pillar One of the OECD/G20 Base Erosion and Profit Shifting (BEPS) framework domestically for fiscal years starting 1 January 2025.
However, the authority confirmed that it will recognise Amount B outcomes in covered jurisdictions with which France has tax treaties, aiming to prevent double taxation arising from its application in those jurisdictions.
Amount B, agreed by the OECD/G20 Inclusive Framework in October 2021, is designed to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities, with a focus on low-capacity jurisdictions. The OECD Transfer Pricing Guidelines 2022 include guidance on “special considerations for baseline distribution activities,” offering a simplified pricing framework and compliance approach.
Earlier, France announced on 23 July 2025 that it will limit the use of the OECD’s simplified transfer pricing method, Amount B, to transactions with developing nations that have adopted the method and have a bilateral tax treaty with France.
