The OECD Pillar 1 Amount B Framework came into effect at the beginning of the year. It provides companies engaged in international intra-group trade with a new approach to transfer pricing for internal distribution and promotional activities.
Pillar 1 Amount B is part of the broader OECD and G20 Base Erosion and Profit Shifting (BEPS) initiative, which aims to address the tax challenges posed by the digitalization of globalizing markets. Amount B creates a new approach to transfer pricing for intra-group distribution and promotion activities. Amount B entered into force on 1 January 2025, but the rules require country-specific implementation. Amount B is due to be incorporated into the OECD Transfer Pricing Guidelines. The change is fundamental, as Amount B would represent the first time that member countries are required to comply with the transfer pricing guidelines.
