The OECD Council approved the contents of the 2025 Update to the OECD Model tax Convention on Income and Capital (“OECD MTC”) on 18 November 2025. The most significant update relates t0 permanent establishments in the context of cross border home office arrangements (see our newsletter). In addition to that, it also covers other cross-border […]
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Amount B of Pillar One offers a simplified transfer pricing approach for distribution entities of multinationals that meet certain criteria. In 2024, the OECD published the Amount B guidance, incorporated as an Annex to Chapter IV of the OECD Transfer Pricing Guidelines, and provided lists of covered and qualifying jurisdictions (follow the links to access […]
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Within the framework of the BEPS 2.0 project, the report on Pillar One – Amount B (“Report on Amount B” or “the Report”) was published on 19 February 2024 and incorporated as an Annex to Chapter IV of the OECD Transfer Pricing Guidelines (for further details, please see our previous newsletter). Two supplements to the […]
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Within the framework of the BEPS 2.0 project a preliminary report on Pillar One – Amount B (launch version) was published on 19 February 2024 as a response to the public consultation documents (December 2021 & July 2023). The final report, including the outstanding work currently being completed, was expected by the end of March […]
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Under the BEPS 2.0 project the OECD published another public consultation document on Amount B of Pillar One on 17 July 2023. Stakeholders were invited to provide input until 1 September 2023. The declared goal of Amount B is to simplify and streamline the application of transfer pricing regulations for baseline marketing and distribution activities, […]
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