- Amount A of Pillar One proposes the re-allocation of taxing rights to market countries. It applies to businesses with global revenues above €20bn - 25% of group’s global residual accounting profit over 10% margin reallocated to markets. Requires US participation.
- A final report was issued in February 2024 on ‘Pillar One – Amount B’ outlining a new process for pricing baseline distribution activities in accordance with the arm’s length principle.
- Timing: this is an area of ongoing negotiation. Amount B applies from 1 January 2025 in countries that opt to apply it.
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