Amount B is an integral part of the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, agreed by the OECD/G20 Inclusive Framework on BEPS in October 2021. It introduces a simplified and streamlined approach for applying the arm’s length principle to baseline marketing and distribution activities, with a particular focus on low-capacity jurisdictions. This approach has been incorporated into the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as an annex to Chapter IV as of the publication of the Amount B Report on 19 February 2024. 

Article 7 of the OECD Model Tax Convention on Income and on Capital provides the international tax principles for attributing profits to a permanent establishment. The Authorised OECD Approach developed in the 2010 Report on the Attribution of Profits to Permanent Establishments relies on the separate entity and the arm‘s length principles to attribute profits based on the functions performed, assets used, and risks assumed within a jurisdiction.

Transfer Pricing Country Profiles are intended to reflect the state of countries' legislations. By outlining jurisdictions’ approaches, these profiles help multinational enterprises and other stakeholders navigate varying transfer pricing frameworks. They also serve as a valuable resource for tax administrations, promoting consistency and transparency in applying the arm’s length principle globally. 

Country-by-Country Reporting (CbCR) is a key outcome of BEPS Action 13, incorporated in Chapter V of the OECD Transfer Pricing Guidelines. It is a minimum standard of the BEPS project and has been introduced by over 115 jurisdictions worldwide.

CbCR is designed to provide tax administrations with a comprehensive overview of multinational enterprises' global allocation of income, taxes, and business activities. This reporting framework helps identify potential transfer pricing risks to ensure that profits are taxed where economic activities and value creation occur. By enhancing transparency, CbCR promotes greater compliance and trust between taxpayers and tax administrations, supporting fair and efficient international tax practices.