Tax challenges arising from digitalisation: Public comments received on Amount B under Pillar One relating to the simplification of transfer pricing rules


20/09/2023 – On 17 July 2023, as part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD invited 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 OECD is grateful to the commentators for their input and now publishes the public comments received.


  • Download the comments (Zip file, 21MB - Please open from a desktop computer) - Updated 26 September 2023 with additional comments


For more information on the OECD's public consultations on tax matters, visit


Enquiries should be addressed to [email protected].


Related Documents