Base erosion and profit shifting

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


17/07/2023 – 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 and following the agreed Outcome Statement, the OECD is seeking public comments on Amount B under Pillar One.


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 (also available in French) outlines the design elements of Amount B and is released in order to obtain inputs from stakeholders on the technical aspects of Amount B. As highlighted in the Outcome Statement, further work will be undertaken on the following aspects:

  • Ensuring an appropriate balance between a quantitative and qualitative approach in identifying baseline distribution activities;
  • The appropriateness of:
    • the pricing framework, including in light of the final agreement on scope;
    • the application of the framework to the wholesale distribution of digital goods;
    • country uplifts within geographic markets; and
    • the criteria to apply Amount B utilising a local database in certain jurisdictions.


Interested parties are invited to submit their comments* on this discussion draft with a particular focus on the issues identified above by 1 September 2023. Due to the high volume of anticipated submissions, stakeholders are encouraged to send in their comments in the form of a questionnaire. If this is not possible, comments should be sent by email to [email protected] 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.



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.


Given that open issues remain, the proposals included in this consultation document do not represent the consensus views of the Inclusive Framework on BEPS, 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.