- Amount A of Pillar One concerns the re-allocation of taxing rights to market countries. It applies to businesses with global revenues above €20bn - 25% of group’s global residual accounting profit over 10% margin reallocated to markets.
- No new digital services taxes (DSTs) are to be introduced, and existing DSTs are to be repealed – standstill previously extended to 31 December 2024 subject to a ‘critical mass’ of countries signing up to Amount A by the end of 2023. Work is ongoing at the OECD Inclusive Framework.
- A report was issued in February 2024 on ‘Pillar One – Amount B’ outlining a new process for pricing baseline distribution activities in accordance with the arm’s length principle.
- Timing: the OECD Inclusive Framework is working towards finalising a new multilateral convention for Amount A , which will enter into force once it has been ratified through domestic processes by a critical mass of countries. Amount B will apply from 1 January 2025 in countries that opt to apply it.
Resources (click to open)
- OECD Pillar One: Additional Amount B guidance published (Deloitte tax@hand, June 2024)
- OECD Pillar One: Report issued on Amount B, simplification of transfer pricing rules (Deloitte tax@hand, February 2024)
- OECD Pillar One—Amount A Multilateral Convention (Deloitte tax@hand, October 2023)
- Update On Latest OECD Developments: Pillar One and Pillar Two (Deloitte EMEA Dbriefs webcast, August 2023)
- OECD Pillar One: Amount B report and public consultation (Deloitte tax@hand, July 2023)
- OECD Inclusive Framework publishes outcome statement on Pillar One and Pillar Two (Deloitte tax@hand, July 2023)
- OECD Pillar One: Amount B Transfer Pricing Distribution return (Deloitte EMEA Dbriefs webcast, 20 January 2023)
- OECD Pillar One: Consultation on Amount B transfer pricing distribution return (Deloitte tax@hand, December 2022)
- OECD Pillar One Amount A: Digital services taxes and relevant similar measures (Deloitte tax@hand, December 2022)
- The tax rules that lie behind Pillar One and Pillar Two (Tax Adviser magazine, November 2022)
- Progress reports on Pillar One and Pillar Two, new public consultation launched (Deloitte tax@hand, October 2022)
- OECD Pillar One Amount A public consultation: Observations and comments (Deloitte tax@hand, July 2022)
- OECD Inclusive Framework updates political agreement on Pillar One and Pillar Two (Deloitte tax@hand, October 2021)
