As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD is seeking public comments on the main design elements of Amount B under Pillar One.

The public consultation document released on Thursday outlines the main design elements of Amount B and was released by the OECD Secretariat in order to obtain inputs from stakeholders on the technical aspects of Amount B. Input from stakeholders is particularly sought with respect to the specific questions laid out in the document.

Interested parties are invited to send their comments on this discussion draft and to respond to the specific questions included in the boxes, by 25 January 2023 by e-mail to [email protected] in Word format. Comments in excess of ten pages should attach an executive summary limited to two pages. Comments should be addressed to the Tax Treaties, Transfer Pricing and Financial Transactions Division, OECD/CTPA.

As part of the Two-Pillar Solution agreed in October 2021, Amount B 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.


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