In this Podcast, Silvana and Mikhail discuss the developments surrounding OECD Amount B guidance as it stands in March 2024.  We explore the scope and criteria of Amount B, emphasizing its focus on tangible goods and excluding digital goods and services. We review the three-step pricing matrix and the industry groupings within the draft. We review the current articulation of the “risk adjustments” proposed in the Amount B paper and discuss its merits.

00:00 Initial Reactions to the Latest Amount B Draft

02:59 The Promise of Simplified Guidance and Its Limitations

03:39 Tracing the Origins: BEPS, Digitalization, and Tax Challenges

10:23 Diving into the Details: Scoping Criteria and Practical Implications

18:15 Analyzing the Pricing Matrix and Industry Groupings

21:52 Addressing Qualifying Jurisdictions and Risk Adjustments

30:03 Concluding Thoughts on Streamlining Transfer Pricing Processes