Tax challenges of digitalisation: OECD invites public input on the design elements of Amount B under Pillar One relating to the simplification of transfer pricing rules


08/12/2022 – As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD is seeking public comments on the main design elements of Amount B under Pillar One.


As part of the Two-Pillar Solution agreed 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.


The public consultation document released today (également disponible en français) outlines the main design elements of Amount B and is released by the OECD Secretariat in order to obtain inputs from stakeholders on the technical aspects of Amount B. Input from stakeholders is particularly sought with respect to the specific questions laid out in the document.


Interested parties are invited to send their comments* on this discussion draft and to respond to the specific questions included in the boxes, by 25 January 2023 by e-mail to in Word format. Comments in excess of ten pages should attach an executive summary limited to two pages. Comments should be addressed to the Tax Treaties, Transfer Pricing and Financial Transactions Division, OECD/CTPA.


Register for the live webinar on Thursday, 8 December, at 17:00 CET / 11:00 EST for a presentation on the main features of the draft rules.


Watch the replay


Further information on the two-pillar solution for addressing the tax challenges arising from digitalisation and globalisation of the economy is available at


For more information or inquiries, please contact Manuel De Los Santos, Head of the Transfer Pricing Unit or the Communications Office at the OECD Centre for Tax Policy and Administration.


The proposals included in this consultation document have been prepared by the OECD Secretariat, and do not represent the consensus views of the Inclusive Framework, the Committee on Fiscal Affairs or their subsidiary bodies.


*Please note that all written comments received will be made publicly available. Comments submitted in the name of a collective "grouping" or "coalition", or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting.