The African Tax Administration Forum (ATAF) and the OECD recently concluded a successful series of joint workshops on advancing transfer pricing simplification across the African region.
The workshops, attended by 160 tax officials and policymakers from 18 African countries, focused on practical approaches to simplifying the administration of transfer pricing rules, an area where many African tax administrations continue to face challenges due to resource constraints and limited availability of reliable comparables. A key component of the discussions was the OECD’s simplified approach for baseline marketing and distribution activities, known as Amount B, which was incorporated into the OECD Transfer Pricing Guidelines in February 2024.
In total, ATAF and the OECD hosted four virtual workshops that brought together tax officials and policy experts to strengthen their understanding of Amount B and to equip African tax officials and policymakers with the necessary tools to evaluate the potential implementation of Amount B in the region. Participants explored:
- Approaches to providing more certainty and consistency in pricing routine distribution and marketing;
- The use of the OECD’s Pricing Automation Tool to streamline computations of the Amount B return using minimal data inputs;
- The use of the ATAF Suggested Approach to Drafting Transfer Pricing Legislation on guidance to drafting Amount B rules in Domestic Law;
- The potential impact of simplified transfer pricing measures on domestic resource mobilisation, tax certainty, investment and growth;
- Practical steps and key considerations for jurisdictions evaluating whether to adopt Amount B.
The strong engagement in these workshops reflects the growing interest among African countries in considering simplified measures such as the Amount B to address persistent transfer pricing disputes related to in-scope baseline marketing and distribution activities, the lack of comparables in the region and the resource constraints faced by many tax administrations in the region.
ATAF and the OECD reaffirm their commitment to supporting African countries through technical assistance, capacity building and digital tools that enhance the efficient application of transfer pricing rules and strengthen domestic resource mobilisation. A new series of workshops on Amount B will be offered early in 2026 in French, for French-speaking African countries, and to individual countries on demand.
For further information on this work, please visit the OECD website https://www.oecd.org/en/topics/sub-issues/transfer-pricing/pillar-one-amount-b.html and ATAF website https://ataftax.org/library/?_sft_publications-subcategories=transfer-pricing.
Queries on the workshops and the related issues should be directed to the OECD Centre for Tax Policy and Administration (ctp.communications@oecd.org) and to ATAF (communication@ataftax.org).