Assessing the Impact of Amount B

On February 19, 2024, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting released a report on Amount B, the OECD’s initiative to simplify and streamline the application of the arm’s length principle (“ALP”) to baseline marketing and distribution activities. The guidance gives jurisdictions the option to apply the Amount B approach from January 2025, either as a taxpayer safe harbor or as a mandatory rule.

As businesses begin to assess the impact of Amount B they are starting to identify unexpected outcomes and potential challenges. This article highlights some of these outcomes and challenges that businesses should consider ...