The OECD has released updated guidance and tools to support the implementation of Amount B, the simplified transfer pricing approach for baseline marketing and distribution activities. The 17 February 2026 package includes nine new FAQs addressing stakeholder questions and a refreshed Excel-based pricing automation tool featuring 2026 sovereign credit rating data.
The OECD published new materials on 17 February 2026 to assist with the rollout of Amount B under Pillar One, which provides a simplified transfer pricing framework for baseline marketing and distribution activities. The release includes updated guidance in the form of FAQs and a revised pricing automation tool.
Amount B is an integral part of the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, agreed by the OECD/G20 Inclusive Framework on BEPS in October 2021. It introduces a simplified and streamlined approach for applying the arm’s length principle to in-country baseline marketing and distribution activities, focusing on the needs of low-capacity jurisdictions. This approach has been incorporated into the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
New FAQs on Amount B pricing
The OECD issued nine frequently asked questions to address technical issues raised by stakeholders. The guidance is designed to promote consistent application of Amount B and builds on the consolidated report published in February 2025. The Amount B Pricing FAQs have been developed in response to technical questions raised by stakeholders and aim to ensure a consistent application of the Amount B simplified and streamlined approach.
Updated pricing automation tool for 2026
An updated version of the pricing automation tool was also released. The Excel-based tool, first introduced in December 2024 and updated annually, automatically calculates the Amount B return for eligible tested parties based on user-input data.
The Pricing Automation Tool for the SSA is a tool developed by the OECD Secretariat to automate the calculations of the return on sales for qualifying transactions under Annex III of Chapter IV of the OECD Transfer Pricing Guidelines. It intends to minimise the administrative and compliance burdens of tax administrations and taxpayers. This tool automatically computes the return (including any adjustment under the Operating Expenses Cross-Check and Data Availability Mechanism) with minimal data inputs.
The 2026 edition incorporates revised inputs required for applying Amount B next year, including updated sovereign credit rating data.
Earlier, the OECD published a comprehensive report on Amount B on 24 February 2025.
