OECD Public Consultation Document on Amount B of Pillar One

The Amount B pricing methodology is being designed to deliver on the mandate of the Inclusive Framework (IF) Statement of October 2021 to simplify and streamline application of the arm’s length principle to in-country baseline marketing and distribution activities, considering the specific needs of low-capacity countries. The pricing methodology will rely on the application of common benchmarking search criteria to identify comparable entities performing baseline marketing and distribution activities drawing upon publicly available corporate financial information.