ATAF RESPONDS TO OECD/G20 INCLUSIVE FRAMEWORK'S REPORT ON PILLAR ONE'S AMOUNT B

FOR IMMEDIATE RELEASE

Press Release 

Pretoria, 19 February 2024,

Today, the OECD/G20 Inclusive Framework (IF) on Base Erosion and Profit Shifting (BEPS) published a report on Amount B of Pillar One. Part of that report will now be incorporated into the OECD Transfer Pricing Guidelines. 



Amount B provides a simplified and streamlined approach to the application of the arm’s length principle to baseline marketing and distribution activities. One notable aspect is the optional nature of this approach, which gives countries the freedom to decide whether to adopt it, even if they are not IF members.

Many African countries have reported to ATAF that they use the OECD Transfer Pricing Guidelines (OECD TPG) in addition to drafting new or revised transfer pricing rules based on the ATAF Suggested Approach to Drafting Transfer Pricing Legislation, to determine arm’s length prices, and consider that including the simplified and streamlined approach will greatly assist them in dealing with the pricing of baseline marketing and distribution activities which are a major source of transfer pricing disputes in their countries. 

To assist ATAF members in enacting changes to their transfer pricing legislation to incorporate the simplified and streamlined approach, ATAF will be revising its own Suggested Approach to Drafting Transfer Pricing Legislation, to include a model text on enacting the approach. 

“Enabling our members to adopt the simplified and streamlined approach seamlessly is crucial to achieving fair and efficient transfer pricing practices. 

The forthcoming revision of our Suggested Approach to Drafting Transfer Pricing Legislation, which will include practical support on how to incorporate the approach into existing legislation, exemplifies our commitment to providing practical support to our members in navigating the evolving landscape of international taxation”, commented Logan Wort, ATAF Executive Secretary. 

For media inquiries or additional information, please contact:

Nshimiyimana Fikiri

Communications Manager, ATAF

Tel: +27636893901

Email: fikirin@ataftax.org 

About ATAF

The African Tax Administration Forum (ATAF) is a platform that brings together African tax administrations to engage in mutually beneficial discussions and capacity-building initiatives. ATAF works towards promoting efficient and effective tax systems that contribute to the sustainable development of African nations.