B金额合并报告：BEPS包容性框架

Consolidated Report onAmount B Inclusive Framework onBEPS Consolidated Reporton Amount B INCLUSIVE FRAMEWORK ON BEPS This document, as well as any data and map included herein, are without prejudice to the status of or sovereignty overany territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. The statistical data for Israel are supplied by and under the responsibility of the relevant Israeli authorities. The use ofsuch data by the OECD is without prejudice to the status of the Golan Heights, East Jerusalem and Israeli settlements inthe West Bank under the terms of international law. Note by the Republic of Türkiye The information in this document with reference to “Cyprus” relates to the southern part of the Island. There is no singleauthority representing both Turkish and Greek Cypriot people on the Island. Türkiye recognises the Turkish Republic ofNorthern Cyprus (TRNC). Until a lasting and equitable solution is found within the context of the United Nations, Türkiyeshall preserve its position concerning the “Cyprus issue”. Note by all the European Union Member States of the OECD and the European UnionThe Republic of Cyprus is recognised by all members of the United Nations with the exception of Türkiye. Theinformation in this document relates to the area under the effective control of the Government of the Republic of Cyprus. OECD (2025),Consolidated Report on Amount B: Inclusive Framework on BEPS, OECD/G20 Base Erosion and Profit ShiftingProject, OECD Publishing, Paris, https://doi.org/10.1787/182b47ad-en. ISBN 978-92-64-36431-8 (print)ISBN 978-92-64-96042-8 (PDF)ISBN 978-92-64-35562-0 (HTML) OECD/G20 Base Erosion and Profit Shifting ProjectISSN 2313-2604 (print)ISSN 2313-2612 (online) Photo credits:Cover © ninog/Fotolia.com. Corrigenda to OECD publications may be found at: https://www.oecd.org/en/publications/support/corrigenda.html.© OECD 2025 Attribution 4.0 International (CC BY 4.0) This work is made available under the Creative Commons Attribution 4.0 International licence. By using this work, you accept to be bound by the terms of this licence(https://creativecommons.org/licenses/by/4.0/).Attribution– you must cite the work.Translations– you must cite the original work, identify changes to the original and add the following text:In the event of any discrepancy between the original work and thetranslation, only the text of original work should be considered valid.Adaptations– you must cite the original work and add the following text:This is an adaptation of an original work by the OECD. The opinions expressed and arguments employed inthis adaptation should not be reported as representing the official views of the OECD or of its Member countries.Third-party material– the licence does not apply to third-party material in the work. If using such material, you are responsible for obtaining permission from the third party and forany claims of infringement.You must not use the OECD logo, visual identity or cover image without express permission or suggest the OECD endorses your use of the work.Any dispute arising under this licence shall be settled by arbitration in accordance with the Permanent Court of Arbitration (PCA) Arbitration Rules 2012. The seat of arbitration shallbe Paris (France). The number of arbitrators shall be one. Foreword In an increasingly globalised economy, multinational enterprises operate expansive value chains spanningseveral countries. As a result, lengthy cross-border tax disputes may arise, especially in relation to baselinemarketing and distribution activities.These disputes often drain the financial and administrative resourcesofall parties involved.This challenge is only amplified for low-capacity jurisdictions whose taxadministrations often grapple with limited resources and unavailable data. This reportprovides guidancedesigned to simplify the application of transfer pricing rules with regards to baseline marketing anddistribution activities, alleviate administrative burden, cut compliance costs, and enhance tax certainty fortax administrations and taxpayers alike. Released in October 2020, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting reportTax Challenges Arising from Digitalisation–Report on Pillar One Blueprintstated that Amount B wasintended to simplify and streamline the application of the arm’s length principle to baseline marketing anddistribution activities, with a focus on the specific needs of low-capacity jurisdictions. In October 2021, theInclusiveFramework agreed a two-pillar solution to address the tax challenges arising from thedigitalisation of the economy. For the past two years, Inclusive Framework members have worked on an equal footing to ensure thatAmountB delivers meaningful simplification to price baseline marketing and distribution activities,considering in particular the challenges that low-capacity jurisdictions face in applying transfer p