Executive summary

On 17 February 2026, the Organisation for Economic Co-operation and Development (OECD) released a document containing Amount B Pricing Frequently Asked Questions (FAQs) and an updated version of the Amount B Pricing Automation Tool. The Amount B Pricing FAQs provide some clarifications on technical questions that stakeholders have raised with respect to the pricing mechanism of Amount B, currently addressing nine questions. The Pricing Automation tool released by the OECD in 2024 to help compute the Amount B return for in-scope distributors has been updated with 2026 data in line with the OECD commitment to perform the annual updates necessary for the application of Amount B.

Detailed discussion

Background

In October 2021, the OECD released a statement reflecting the high-level agreement of Inclusive Framework member jurisdictions on core design elements of Pillars One and Two of the Base Erosion and Profit Shifting (BEPS) 2.0 project. (See EY Global Tax Alert, OECD releases statement updating July conceptual agreement on BEPS 2.0 project, dated 11 October 2021.)

As described in the October 2021 statement, Amount B of Pillar One was intended to simplify and streamline the application of the arm's-length principle to in-country baseline marketing and distribution activities, with a particular focus on the needs of low-capacity countries. The OECD released public consultation documents on Amount B in December 2022 and July 2023, which reflected the ongoing work on Amount B as well as issues that remained open. (See EY Global Tax Alerts, OECD releases public consultation document on Amount B of Pillar One on baseline marketing and distribution functions, dated 15 December 2022, and OECD releases public consultation document on Pillar One Amount B on baseline distribution, dated 26 July 2023.)

On 19 February 2024, the OECD published a report on Amount B, which is incorporated in the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 (OECD TPG). (See EY Global Tax Alert, OECD releases final guidance on Pillar One Amount B on baseline distribution, dated 22 February 2024.) The OECD TPG indicate that jurisdictions can choose to apply the Amount B approach for in-scope transactions of tested parties in their jurisdictions for fiscal years starting on or after 1 January 2025.

On 17 June 2024, the OECD released two documents on Amount B, providing current lists of the jurisdictions that are qualified for specified adjustments to the calculations under the Amount B approach and a current list of the jurisdictions that are covered by the political commitment of Inclusive Framework members to respect the outcome of those jurisdictions' application of Amount B. (See EY Global Tax Alert, OECD/G20 Inclusive Framework releases documents on Pillar One Amount B and Pillar Two, dated 20 June 2024.)

On 20 December 2024, the OECD released a fact sheet with a step-by-step explanation of the application of Amount B and an automated tool for pricing the return on sales for baseline distribution activities under Amount B. (See EY Global Tax Alert, OECD releases fact sheet and automated tool for Pillar One Amount B, dated 20 December 2024.)

On 13 January 2025, the OECD released a statement by the Co-chairs of the Inclusive Framework, providing information regarding the current status of negotiations regarding both Amount A and Amount B of Pillar One. The January 2025 Statement noted that substantial work has been done on the parameters for the Amount B framework, but identified certain outstanding issues remaining among some jurisdictions (e.g., interdependence between the Amount A Multilateral Convention and Amount B, optional qualitative test, pricing matrix outcomes). (See EY Global Tax Alert, Pillar One Update from Co-chairs of Inclusive Framework on BEPS, dated 15 January 2025.)

On 24 February 2025, the OECD published a consolidated Amount B report incorporating the Amount B materials published by the Inclusive Framework from February 2024 through December 2024.

Beginning on 22 May 2025, the OECD published four batches of updated transfer pricing country profiles that include new sections on Amount B.

Detailed discussion

On 17 February 2026, the OECD published:

1. The Amount B Pricing FAQs
2. The 2026 revision of the Pricing Automation Tool

Amount B Pricing FAQs

The Amount B Pricing FAQs provide some clarifications on technical questions stakeholders have raised with respect to the pricing mechanism of Amount B, covering issues that include:

• The accounts payable guardrail
• Relevance of 0.5% range to adjustments provided in Sections 5.2 and 5.3
• Relevance of intercompany debtors and creditors to the calculation of working capital
• Amount B pricing for start-ups or new companies
• Definition of net revenue
• Industry groupings

2026 revision of the Pricing Automation Tool

The Pricing Automation Tool last updated on 17 January 2025 is designed to automatically compute the Amount B return for an in-scope tested party. It is intended to optimize the administrative and simplification benefits of Amount B for tax administrations and taxpayers. The tool is intended to be updated annually to reflect any changes to the pricing matrix and other datapoints relevant to application of Amount B adjustment features.

The latest version reflects updates to the information required for the application of Amount B in 2026, in particular sovereign credit ratings data.

Implications

Businesses should watch for further developments with respect to Amount B because jurisdictions can choose to apply Amount B now. It should be noted there is no revenue threshold limiting the businesses that could be in scope of Amount B. It is important for companies to assess how the jurisdictions that are relevant to their operations react to the implementation of Amount B and how this may affect the pricing of in-scope transactions.

Certain jurisdictions (such as the United States and Singapore) have taken legislative and regulatory steps to signal implementation of Amount B on an elective basis for in-scope taxpayers in their jurisdictions. Some other jurisdictions have expressed an interest in applying Amount B but have not taken legislative steps in this respect (such as South Africa). Other jurisdictions, such as Denmark, France, Germany, Ireland, Norway, the Netherlands, Turkiye and the United Kingdom) have officially confirmed they would respect the outcome of Amount B application to in-scope tested parties by jurisdictions covered by the political commitment under certain conditions.