The OECD has announced the launch of new tools to streamline the implementation of Amount B under Pillar One aimed at simplifying transfer pricing rules.

Amount B under the Two-Pillar Solution to Address the Tax Challenges of the Digitalising Economy provides for a simplified and streamlined approach to the application of the arm’s length principle to in-country baseline marketing and distribution activities, with a particular focus on the needs of low-capacity countries.

This includes:

• The fact sheets provide a high-level overview of the mechanics of Amount B, including the steps taxpayers and tax administrations should take to apply Amount B.
• The Pricing Automation Tool has been developed to automatically compute the Amount B return for an in-scope tested party, requiring only minimal data inputs, and is intended to further optimise the administrative and simplification benefits for both tax administrations and taxpayers. The tool will be updated annually to reflect any changes to the pricing matrix and other data points relevant to the application of Amount B adjustment features. As referenced in the Amount B guidance published in February 2024, jurisdictions can choose to apply the simplified and streamlined approach for in-scope transactions of tested parties in their jurisdictions for fiscal years commencing on or after 1 January 2025. The inclusion of jurisdictions in this tool is illustrative and does not mean any particular jurisdiction has adopted or intends to adopt Amount B. The list of jurisdictions implementing Amount B will be maintained separately.

The adoption of Amount B is still under consideration by many Inclusive Framework members as they take time to complete domestic administrative and legislative procedures along with other competing fiscal priorities in 2025/2026.

Amount B is optional and Inclusive Framework members are encouraged to provide sufficient notice to taxpayers in advance of Amount B coming into effect in their respective jurisdiction. To facilitate coordination, the OECD will maintain a list of countries that have officially confirmed that they will adopt Amount B, including the date of adoption. This list will be maintained on the OECD website and regularly updated as jurisdictions begin to make those formal announcements.

The OECD will hold a technical webinar on 11 February 2025 on the latest developments relating to Amount B, including a demonstration of the Pricing Automation Tool. Registration details will follow shortly.