Deep dive into the OECD’s Pillar One—Amount B

Deep dive into the OECD’s Pillar One—Amount B

Uncertainty and controversy related to tax margins on distribution activities have long been issues on executives’ radars. Pillar One—Amount B aims to fix that. However, tax leaders need to know the potential benefits and risks associated with the proposed process. In this episode, Deloitte Tax Leader and former US Deputy Assistant Secretary for International Tax Affairs Bob Stack joins Tax Transfer Pricing Specialist William Zimmerman to discuss the methodology outlined in the consultation document and the questions businesses will have to think through before the final product is announced mid-2023.

With the consultation document, the OECD is trying to scope out companies that are distributors to standardize margins, but [it] runs the risk that the disputes will not be about the margin on the business but rather ‘Is this company really in scope or not?

—Bob Stack

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