The OECD/G20 Inclusive Framework on BEPS agreed to the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy in October 2021.
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 content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.
Read our summary and commentary on Pillar One – Amount B by click on download button is below:
Jack Sheehan
Partner, Head of Regional Tax
Thailand
Jack is a Partner and Tax Leader at the firm.
