Episode 107: Pillar One Amount B: A fragmented future written in the tea leaves

In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice), Kartikeya Singh (Principal in PwC’s US National Tax Services Transfer Pricing Practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) continue the discussion on Amount B of the OECD’s Pillar One initiative, focusing on the latest developments, including the OECD’s Amount B final report from February of this year, and the follow-up guidance released in June 2024.   

Timestamps:

• 01:56 - Recap of the key elements from the OECD July 2023 consultation document and how it moved the discussion forward.

• 04:17 - Regarding the OECD’s February final report on Amount B, where did the OECD land in terms of whether Amount B will be mandatory or optional for countries?

• 07:28 - Given the different options and the potential for a fragmented compliance landscape, can you talk about the complexities this might bring for taxpayers?

• 09:29 - Aside from the implementation options, what were some of the key changes or evolutions in the February report compared to the July Consultation document? In the previous podcast we discussed Alternative A and Alternative B with respect to the scoping criteria.  Were there any notable changes there?

• 11:24 - If we still need to do a full FAR analysis plus two additional steps, where exactly is the simplification here?

• 13:02 - Let’s focus on the specifics of the pricing matrix in the February final report.  Were there any significant updates or modifications compared to the July consultation document?  And how do these changes impact taxpayers?

• 17:04 - Let’s touch on the supplementary guidance the OECD released in June. Can you walk us through what was included in this guidance and what does it mean for different jurisdictions?

• 19:52 - Regarding these three different lists of jurisdictions that were part of the supplementary guidance in June, what is the Inclusive Framework trying to achieve?

• 21:09 - Given the latest June guidance, where do things stand now? What are the main concerns or reservations being expressed by both taxpayers and countries?     

• 25:41 - What about the United States? What is the current stance of the US on Amount B, and how does it align or conflict with the positions of other major jurisdictions?  Do you foresee any significant challenges or support in the near future?

• 28:37 - Given the fragmented approach to amount B, what can or should in-scope companies be doing now to prepare for Amount B?  What are some practical steps they can take to navigate this evolving landscape?

See also: Pillar One Amount B: Reading the tea leaves

Contacts:  Kristina Novak, Kartikeya Singh, Giorgia Maffini