Gilles Franssens’ Post

Amount B seems to be closing 2024 on a high. Yesterday, the IRS issued a notice for regulations which aims to introduce Amount B as a part of the US regs for taxable years beginning on or after 1 January 2025. At a minimum, it would be introduced as a safe harbour for taxpayers but the IRS is still considering making its application mandatory. As a recap, amount B is a new Transfer Pricing mechanism to determine the remuneration for 'routine' marketing and distribution activities in certain sectors. We will be covering this topic in depth (including the positions taken by other countries) during our upcoming international tax webinar early February. Just send me a DM if you'd like an invite for this webinar!