Pillar One, Amount B: Current Implications and Future Perspectives

Abstract

On 17 July 2023, the OECD released an updated version of the Amount B draft report for public consultation. This article examines the current extended scope of Amount B, analysing the main implications on the transfer pricing methodologies – especially the TNMM – and explores, among others by means of numeric examples, the broader implications of Amount B, should the scope be further enlarged in the future. Some broader issues about the interactions between Amount B and Amount A under Pillar One are also addressed.