Pillar One: Amount B
Amount B introduces a simplified and standardized transfer pricing method for baseline marketing and distribution activities that are routine and low-risk. We assist multinational enterprises in evaluating the applicability of Amount B to their distribution models across jurisdictions, assessing whether their current policies align with OECD guidelines.
Our services include monitoring global implementation progress, modeling potential outcomes through pilot assessments, and identifying necessary adjustments to existing pricing frameworks. With our strategic insights, clients can proactively adapt their transfer pricing policies to reduce uncertainty and enhance cross-border compliance.
Pillar Two: Global Minimum Tax
Pillar Two enforces a global minimum tax rate of 15% for large multinational groups. Where an entity’s effective tax rate falls below the threshold, top-up tax may be triggered. We support clients in re-evaluating and restructuring their global operating models to comply with the Global Anti-Base Erosion (GloBE) rules while minimizing incremental tax exposure.
Our lawyers provide comprehensive guidance on technically complex issues such as scoping under GloBE, pre-tax profit and loss adjustments, substance-based income exclusions, determination of covered taxes, application of the undertaxed payments rule (UTPR), and strategic use of the 15 available elections under the GloBE framework.
