How can PwC Belgium help you become #AmountBReady?

Pillar One Amount B Readiness

pillar one
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Does your tax model remain sustainable in light of Amount B? Do you know its impact across your value chain? Are you ready to gather the necessary financial data?

What is Amount B?

On 19 February 2024, the OECD published a report which aims to simplify and streamline the application of the arm's length principle to in-country baseline marketing and distribution activities (the Report) (also known as Amount B under Pillar One) by establishing a fixed Return on Sales (RoS), ranging from 1.5% - 5.5% (+/- 0.5%).

Amount B is meant to apply to virtually all industries selling (tangible or digital) goods in a wholesale context, and does not foresee any revenue thresholds for its application.


sustainable tax strategy dashboard
sustainable tax strategy dashboard

When does Amount B come into effect?

The Amount B guidance is incorporated in the OECD Transfer Pricing Guidelines (TPG) and can be applied for in-scope transactions for fiscal years commencing on or after 1 January 2025. Although it’s soft law, these guidelines have direct effect in many countries’ local law (and tax treaties), meaning that no local legislative process is required prior to implementation. Amount B could also be used as a resolution tool in MAP cases under certain conditions.

Therefore, it’s important to understand and evaluate the (potential) impact of Amount B on your organisation’s value chain.

How does Amount B work?

Amount B applies to baseline buy-sell marketing and distribution, sales agency and commissionnaire activities for wholesale distribution of (tangible or digital) goods.

A qualifying transaction for purposes of Amount B is characterised by:

  • Involvement in external sales
    • Buy-sell activities, commissionaires and sales agents are in scope of Amount B.
  • Baseline activities & application of a one-sided method:
    • The transaction must be able to be reliably priced using a one-sided transfer pricing method under the OECD TPG (e.g., TNMM), with the distributor, sales agent or commissionnaire being the tested party. The tested party must not have an annual opex/sales ratio lower than 3% and greater than 30% (Alternative A) or 50% (Alternative B), based on a three-year weighted average.
    • The transaction must not involve unique and valuable intangibles and/or economically significant risks. The exact definition of baseline is subject to further consultation (i.e., Alternative A / B).
  • Wholesale distribution:
    • Retail distribution to end-customers is outside Amount’s B scope, (a de-minimis is in place whereby the overall net revenues can consist of a maximum of 20% retail sales).
  • Tangible (and digital) goods:
    •  Non-tangible goods, commodities and services are outside Amount B’s scope.

Several exceptions to Amount B’s scope are foreseen, like the availability of internal CUPs to price a transaction. 

The pricing matrix determines the target RoS for in-scope activities. The matrix is characterised by two dimensions, i.e. industry grouping and factor intensity, and lists a total of 15 RoS price points. 

The target RoS pricing is further corroborated by an implied Berry Ratio test that sets out an overall 1.5 Berry ratio ceiling and 1.05 Berry ratio floor to be applied. 

Deviating pricing matrices may apply for a number of countries and therefore override its application.

Amount B Impact Assessment Tool

The Amount B Impact Assessment Tool can help you to assess the impact of Amount B on your tax model. It is an interactive tool that quantifies and visualises the anticipated financial impact of the introduction of Amount B from both a local and central perspective. Please see below for more details.

amount b dashboard
amount b dashboard
amount b dashboard

How can PwC assist you in the road towards Amount B readiness?

PwC professionals are happy to help determine if and how Amount B implementation would impact your organisation and tax model, as well as assist with the financial data (gathering) to be able to assess the impact thereof. Below you can find an impression of our Amount B tooling; 

Qualitative analysis

Consider whether your activities fall within the scope of Amount B. If not, could there still be any indirect impact on entities performing other (out-of-scope) activities?

Quantitative analysis

Determine your RoS% per in-scope activity; determine and test various financial ratios. This is the starting point to assess the impact of Amount B on an entity, country and/or group level.


Review documentation for in-scope activities to be able to reflect Amount B (e.g., intercompany agreements, TP documentation (specifically, local files), APAs, et al).

Tax certainty

Review current, ongoing and future unilateral, bilateral or multilateral agreement proceedings with tax administrations to reflect Amount B where needed.

Operational readiness

Assess whether your current processes enable you to obtain the necessary data considering segmentation, ratio testing, etc.

Interaction with other tax domains

Assess whether the implementation of Amount B on your structure would lead to spill-over impact in other tax domains such as customs and other types of indirect tax.

Contact us

Gilles Franssens

Gilles Franssens

Director, PwC Belgium