The Ongoing Journey of Amount B

Jessie Coleman, transfer pricing principal with KPMG, once again joined our “GILTI Conscience” podcast for a detailed discussion on Amount B as part of Pillar One, as well as a look at the broader international tax landscape on the horizon. Hosts David Farhat and Nate Carden lead the transfer pricing discussion, along with associates Eman Cuyler and Stefane Victor. The conversation was a continuation from our June 2023 episode on Amount B.
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Amount B is designed to streamline transfer pricing for baseline distribution and marketing companies worldwide, but “we’re apparently in a world of complexity and controversy,” says Jessie Coleman.
A principal at KPMG, Jessie joins Skadden attorneys Nate Carden, David Farhat, Eman Cuyler and Stefane Victor to discuss everything there is to know about the current and future status of Amount B. Together, they explore questions of scoping - will jurisdictions agree that an entity is in-scope? - and who’s signing on to Amount B, as well as tensions that may arise over how to handle disputes.
For companies that would likely be in-scope when implementation launches, Jessie suggests they prepare by monitoring their assets-to-sales, which will drive where they fit in the Amount B matrix. “I think knowing the unknown right now is really important,” she observes.
Key Points
The A-B Disconnect: Only the largest companies apply for Amount A, while there is no size threshold on Amount B - meaning a company could be any size as long as it's a wholesale distributor and it passes quantitative screening.
The Question of Scope: Jessie notes that the Amount B guidance released this year didn’t clarify questions of qualitative scoping, an omission that complicates the initiative.
Win for Developing Countries: The ATAF, for one, says that Amount B is good for developing countries, which often don’t have the resources to analyze transfer pricing. Jessie sees it as a win in terms of time and savings for such jurisdictions.