Pillar 1: Amount B - How to

In this week's video we look at the calculations for low risk routine distributors under amount B. The guidance, which will become part of the Annexes to chapter IV of the OECD Transfer Pricing Guidelines were published in February 2024. Although there are a number of steps to follow, the calculations are doable and should save MNEs benchmarking fees. Next on the wish list, the same for same for toll and contract manufacturing please.
Our next video will deal with the formal aspects of Amount B
Want to learn more about International corporate income tax or Transfer pricing? See • Our CIOT ADIT tax cour... and our courses at bettertax.info. For more detail on our international tax course see • International tax cour... , for transfer pricing see • Transfer pricing cours...
OECD Guidance
www.oecd.org/t...

[@jamesmcclure5947]

An issue with the matrix - if OA/Sales > 15% then OE/Sales does not matter. Which is weird if one thinks higher functions should be compensated with a higher margin.

[@RobertStudley-p3i]

Kiarra Village