Amount B: Intent to Introduce Simplicity Culminates in Complexity
- Kuldeep Sharma
- Oct 10
- 1 min read
As the title of the article suggests, it has been inter alia concluded with the help of illustrations that the operating expense cross-check may lead to inconsistent results which damage the very architecture of Amount B rules. The complexity increases as the Consolidated Report on Amount B, 2025 does not discuss the interaction of in-country baseline marketing and distribution activities with the permanent establishment provisions, which may cause litigation and defeat the very purpose of these rules. Further, the article illustratively explains the interaction of Amount B and GloBE Rules.
Tax Administrations intending to implement Amount B rules, MNEs and all interested stakeholders may access the article at the link given below:
Comments