Amount B: (Not So) Simplified and Streamlined Approach

On February 19, 2024, the global tax landscape witnessed a significant milestone with the OECD/Inclusive Framework (IF) unveiling the OECD’s final report on the simplified and streamlined approach (SSA), previously known as Amount B (OECD, Pillar One — Amount B: Inclusive Framework on BEPS, OECD/G20 Base Erosion and Profit Shifting Project (OECD Publishing, Paris 2024)). This initiative, aiming to streamline the application of the arm’s length principle (ALP) for specific baseline distribution and marketing activities, is a critical element of the Pillar One project. By introducing the SSA, the OECD aims to mitigate the complexities and ambiguities often associated with ...