Let It (Amount) B

Amount B is a unique opportunity to increase tax certainty and at the same time reduce compliance costs. It should be seen as a tool to reduce the level of subjectivity for almost all transfer pricing analyses. Although the OECD has made a great effort in developing the approaches proposed in the 2022 Pillar One Consultation Document, it should go a courageous step further and broaden the scope in order to make Amount B more effective and enable it to achieve its aim.