Get ready for Amount B

As global tax rules evolve under the Organisation for Economic Co-operation and Development (OECD)’s Pillar One framework, Amount B aims to simplify transfer pricing for routine distribution activities — but complexity and risk remain. 

Kirsty noted that firms should be prepared for scenarios that have a higher possibility of resulting in double taxation. She elaborated, "For high-risk scenarios, the first line of defence against double taxation is documentation. Accurately delineating the transactions and clearly showing whether a transaction is in or out of scope for Amount B is important." 

On the note of risks, Jonathan highlighted that companies should begin conducting Amount B impact assessments to identify potential risks and opportunities ahead of implementation. 

"The benefit of doing this will be to highlight potential risks and exposures to additional corporate income tax liabilities, where the current level of return for the distribution entity is lower than the expected level of return to be calculated under Amount B," he added. 

Read the full article on AB Magazine 

How we can help 

At Forvis Mazars, we help businesses navigate the complexities of OECD Pillar One Amount B with confidence. From impact assessments and benchmarking to robust transfer pricing documentation, our transfer pricing experts ensure compliance while minimising double taxation risks. Get in touch to safeguard your distribution activities and stay ahead of regulatory changes.