Pillar One - Amount B : Inclusive Framework on BEPS / OECD.

Format:

Book

Author/Creator:

Organisation for Economic Co-operation and Development, author, issuing body.

Series:

OECD/G20 Base Erosion and Profit Shifting Project (Series)

OECD/G20 Base Erosion and Profit Shifting Project

Language:

English

Subjects (All):

Transfer pricing.

Physical Description:

1 online resource.

Place of Publication:

Paris : OECD Publishing, 2024.

Summary:

As part of the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy agreed by the OECD/G20 Inclusive Framework on BEPS 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. Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.

Contents:

Foreword

Executive Summary

Introduction

Special considerations for baseline distribution activities

1 Introduction

2 Considerations regarding the application of the simplified and streamlined approach

3 Transactions in scope

4 Application of the most appropriate method principle to in-scope transactions

5 Determining the return under the simplified and streamlined approach

6 Documentation

7 Transitional issues

8 Tax certainty and elimination of double taxation

Appendix A - Relevant benchmarking search criteria

Appendix B - Illustrative examples

TABLES.

Notes:

Description based on publisher supplied metadata and other sources.

ISBN:

92-64-64711-2