Amount B was heralded as one of the most practical outputs of the OECD's Two-Pillar project: a simplified, low-cost method for pricing routine marketing and distribution activities that would reduce disputes, particularly for lower-capacity jurisdictions. A year into its optional availability, the reality is more complicated, a patchwork of adoption, opt-outs, and elective procedures that challenges the very simplification it promised.
How Amount B Works
Amount B applies the arm's length principle to "in-scope" transactions involving baseline marketing distributors, wholesalers, sales agents, and commissionaires engaged in routine distribution of goods. Instead of conducting a full benchmarking exercise, eligible distributors apply a fixed return on sales from a reference matrix, with margins the OECD suggests range between 1.5% and 5.5% depending on the distributor type and country-specific adjustments. The Consolidated Report on Amount B was published on February 24, 2025, incorporating the framework into the OECD Transfer Pricing Guidelines.
Amount B is designed specifically for routine distributors. It does not apply to distributors that also perform significant non-distribution functions, own valuable intangibles, or assume material financial risks. Companies must self-assess eligibility before applying the fixed-margin approach.
The Opt-Out Problem
Australia, New Zealand, Norway, and Turkey have all formally opted out of Amount B. This creates a significant bilateral complication: a Singapore-based parent applying the SSA to a transaction with its Australian distributor cannot rely on Amount B because Australia has not adopted it. The receiving jurisdiction may apply its own traditional benchmarking approach, potentially resulting in double taxation rather than the simplification Amount B intended. For MNEs with distribution networks spanning both adopting and non-adopting jurisdictions, a transaction-by-transaction eligibility analysis remains essential.
US Adoption: Elective via Notice 2025-04
The US adopted Amount B on an elective basis through IRS Notice 2025-04, allowing MNEs to rely on the simplified approach for baseline marketing and distribution activities for taxable years beginning on or after January 1, 2025. This partial adoption means that US-parented groups may use Amount B for their outbound distribution relationships where both jurisdictions have adopted the approach, but cannot rely on it universally.
OECD Country Profile Updates: A Rolling Picture
The OECD has been releasing updated country profiles in batches throughout 2025 and into 2026. The third batch, published January 16, 2026, brings the total count to over 78 jurisdictions. Each profile now contains dedicated sections on hard-to-value intangibles and the SSA, providing a jurisdiction-by-jurisdiction overview of adoption status that practitioners can use to map their Amount B eligibility across complex global distribution networks.
