Amount B aims to standardise the remuneration of related party distributors that perform "baseline marketing and distribution activities" in a manner that is aligned with the arm's length principle. It is intended to simplify the administration of transfer pricing rules for tax administrations, reduce compliance costs for taxpayers and enhance tax certainty and reduce controversy between tax administrations and taxpayers. This paper provides a detailed overview of Amount B and explore:
The key design features, including:
- What entities and transactions will be captured by (or excluded from) Amount B
- What are baseline marketing and distribution activities?
- The proposed remuneration for baseline marketing and distribution activities
- The current timetable for implementation, next steps and technical work yet to be finalised
- What tax and transfer pricing leaders should be thinking about now