Episode 98: Pillar One Amount B: Reading the tea leaves

August 29, 2023


In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Practice), Kartikeya Singh (Principal in PwC’s US National Tax Practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the OECD’s recent Public Consultation document on Amount B of Pillar One and the details of the progress made since the December 2022 consultation.


1:17 - What is Pillar 1 and what is Amount B under Pillar 1?

3:30 - Can you bring our listeners up to speed on what has happened since the December 2022 consultation document on Amount B?

5:23 - Can you provide more detail on what was covered in the July consultation document and how the draft may have taken previous input submitted in response to the December consultation document?  

12:32 - There seems to be a point of disagreement among the countries on the two scoping alternatives (alternative A and alternative B). Can you explain why that is and tell us more about the different alternatives?

18:26 - There appears to be an overly meticulous justification for obstructing a project with potentially significant benefits; what are your thoughts on that?

20:30 - The stated goals for Amount B were certainty and simplicity. Are we on the road to achieving those goals, and does Amount B actually address the real underlying causes of all the controversy related to routine distributors? 

25:06 - Regarding the July consultation document, you had mentioned that the Pricing Matrix is the “core” of Amount B. Can you explain how it works?

31:57 - What questions have you been getting from taxpayers since the release of the July consultation document? What concerns them the most?

35:30 - What are some takeaways that you can offer our listeners?

Contacts: Kristina NovakKartikeya SinghGiorgia Maffini

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Horacio Peña

Global Transfer Pricing Leader, PwC United States

Tel: +1 (917) 478-5817

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