UvA Tax LLM Webinar 6

The ‘simplified approach’ for baseline distribution activities, officially included in the OECD Transfer Pricing Guidelines and part of work on Pillar One – Amount B, will be officially in place since January 2025. While the ‘go live’ is incipient, doubts arise as to whether this approach would effectively constitute a simplification. On one hand, jurisdictions may asymmetrically opt or out, increasing uncertainty of treatment. On the other, asymmetries may generate from implementation mechanisms chosen and thresholds. And even when there would be a perfect match, doubts may arise regarding segmentation of accounts, performance of year end adjustments, effects on indirect taxes, etc.

During the webinar, we will begin exploring some hiccups that taxpayers may face in different scenarios, showing that beginning simulations and structuring activities is particularly important.