While, transposition of Pillar 2 in Europe is reaching the final phase, ongoing work on negotiating the final technical aspects of Pillar 1 is ongoing. The OECD have published the submissions received from its most recent public consultation, launched in July. Arthur Cox is part of a group of leading tax practices that contributed a submission to the consultation.  The OECD has indicated that it aims for the Inclusive Framework to conclude the work on Amount B by the end of the year, with this final report on Amount B planned to be incorporated into the OECD Transfer Pricing Guidelines by January 2024.

Pillar 1 has two elements; Amount A seeks to redistribute excess profits from large multinational groups to the market jurisdiction, while Amount B seeks to streamline and simplify transfer pricing rules for certain baseline marketing and distribution activities in order to lessen tax controversy and increase tax certainty for all taxpayers. The OECD has published a high level summary of Pillar One Amount B in a Nutshell.