As part of the Two-Pillar Solution to Address the Tax Challenges Arising from the
Digitalisation of the Economy agreed by the OECD/G20 Inclusive Framework on BEPS in
October 2021, Amount B 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. Content from the report
has now been incorporated into the OECD Transfer Pricing Guidelines.
Published on February 19, 2024Also available in: French
In series:OECD/G20 Base Erosion and Profit Shifting Projectview more titles