The OECD Pillar 1 Amount B Tax Changes: What Companies Need to Know

As global taxation frameworks keep changing, one thing is clear: things are going to change for all companies. The OECD’s updates on Pillar 1 Amount B are having an impact on how you operate across borders. Staying informed and preparing yourself isn’t sufficient advice anymore, it’s a necessity for keeping your company compliant and fine-tuning your tax strategies.
These updates will affect every business with international operations in baseline marketing and distribution, no matter the size. Be aware, time is running out for you to prepare! In this blog, we’ll break down the latest OECD updates and show you exactly what you can do to stay ahead.
OECD’s Pillar 1 Amount B, What is it?
The OECD is working on new global tax rules as part of its Base Erosion and Profit Shifting (BEPS) project. Pillar 1 is focused on solving the tax collection issues that arise due to the digital world. Amount B, under Pillar 1, sets basic profit levels for baseline distribution and marketing activities.
What makes Pillar 1 Amount B different? It’s not just targeting the largest multinational enterprises (MNEs). Instead, it will affect any business with cross-border activities, regardless of its size. This broader scope means that even smaller companies with foreign subsidiaries or branches will need to have a look at these new tax rules.
The finalization of Pillar 1 Amount B is expected to be here any day now. Implementation could begin as early as 2025, leaving you a limited window to prepare.
Why these changes matter to your business
You need to see that Amount B will directly influence how profits from baseline distribution and marketing activities are taxed across different jurisdictions. If your company engages in cross-border baseline sales, marketing, or distribution, these changes are important for you.
Under the proposed framework, profits earned from these activities would be subject to a standardized benchmark rate of return. This means the tax authorities in each country will calculate your taxable income based on a predetermined profit margin for routine functions like distribution. The goal is to simplify tax compliance, but if you are used to negotiating transfer pricing based on actual costs and revenues, this shift will probably require an overhaul of your current tax strategies.
This approach aims to provide greater certainty and reduce disputes between companies and tax authorities. However, it could also mean that businesses lose some flexibility in how they report profits, particularly in jurisdictions where they previously benefited from lower tax rates or favorable transfer pricing policies.
Global impact: Who will be affected?
You will need to prepare for increased scrutiny from tax authorities, especially if you are in a market where they have significant baseline distribution and marketing activities. It’s also expected that more countries will sign on to this agreement as the OECD finalizes the details.
Additionally, the digital economy will not be the only sector impacted. Retail, manufacturing, pharmaceuticals, and other industries with significant international sales will need to comply with Amount B’s profit allocation rules.
Timing and what to do now
The timeline is tight, with final guidelines set to be released soon, and enforcement likely to start in 2025. This gives businesses a small window to prepare. If you delay in adapting to these changes you might find yourself scrambling to comply at the last minute, leading to costly errors or penalties.
So, what should your business do?

- Assess Current Tax Structures: Take a close look at how your company currently allocates profits from distribution and marketing activities. Are these profits likely to be impacted by the OECD’s new standard return rate?
- Consult with Tax Experts: Given the complexity of these rules, now is the time to engage with tax consultants who are well-versed in transfer pricing and international taxation. They can help you navigate the upcoming changes and optimize your strategies to maintain compliance while minimizing tax liabilities.
- Prepare for Increased Compliance: The OECD’s goal with Amount B is to create a system that is simpler and more transparent. However, in the short term, this will mean adjusting internal processes to ensure that your tax reporting aligns with the new guidelines.
- Stay Informed: Tax policies are complex, and it’s easy to miss crucial updates. Staying informed about the OECD’s progress on Pillar 1 Amount B will help you avoid surprises. Subscribe to updates from reliable sources and sign up for newsletters like Coperitas to ensure you receive timely insights into these changes.
- Software and tools: Software like Coperitas can provide you with a comprehensive, automated solution for structured information to adapt quickly to the upcoming OECD Pillar 1 Amount B tax changes. Ensuring a simple overview of key information, compliance, reducing manual work, and mitigating risks.
Key takeaways of Pillar 1 Amount B
The changes coming with OECD’s Pillar 1 Amount B are not just an issue for large multinational corporations; they will affect any company with international baseline distribution and marketing operations. By standardizing how profits from distribution and marketing activities are taxed, the OECD aims to create a fairer and more predictable tax environment. But for businesses, this means adapting quickly to avoid being caught off guard.
Don’t wait until the last minute to start preparing. The first deadline may approach fast, and implementation is likely to begin in 2025. Use this time wisely by assessing your current tax structures, engaging with tax professionals, and staying informed about any additional updates from the OECD.
If you want to avoid being left behind when these changes take effect, start preparing now.
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