On February 19, 2024, the OECD Inclusive Framework on BEPS published its long-awaited final report on Pillar One – Amount B.[i]  The report details guidance on the “simplified and streamlined approach” (formerly known as Amount B) for applying the arm’s length principle to certain “baseline marketing and distribution activities.”  While offering some potential benefits in terms of reducing the need for comparables analyses and avoiding some disputes about comparables selection and adjustments, it is nevertheless narrow in scope, complex in application, and will likely give rise to inconsistencies in implementation throughout the world and more controversy. Continue Reading Amount B: Some Benefits, More Burdens