OECD seeking input on Amount B under Pillar 1 tax rules

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The OECD is consulting stakeholders on a vital aspect of its two-pillar solution to address digital economy taxation.

Amount B under Pillar 1 rules 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.

The OECD is seeking comments on the design elements of Amount B. Input is requested on ensuring an appropriate balance between a quantitative and qualitative approach in identifying baseline distribution activities.

The OECD is also seeking input on the appropriateness of:

  • the pricing framework, including in light of the final agreement on scope
  • the application of the framework to the wholesale distribution of digital goods
  • country uplifts within geographic markets; and
  • the criteria to apply Amount B utilising a local database in certain jurisdictions.

Comments must be received by September 1, 2023.