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July 11, 2023

OECD releases IF Pillar One progress statement

On July 12, the OECD published a press release and an "Outcome Statement" reflecting that the Inclusive Framework has made significant progress but has not reached a final agreement on Pillar One and that once a "small number of specific items are resolved" they will deliver a final Multilateral Convention (MLC) to be agreed by the end of the year. Both documents are attached below. The Outcome Statement notes:

Amount A

  • The Inclusive Framework has delivered a text of a Multilateral Convention (MLC) (with a few unidentified open items), which will allow the Parties to the MLC to exercise a domestic taxing right (Amount A of Pillar One). The MLC will be opened in the second half of 2023 and a signing ceremony will be organized by year end, with the objective of enabling the MLC to enter into force in 2025.
  • Importantly, members of the Inclusive Framework agree to refrain from imposing newly enacted DSTs or relevant similar measures, as defined in the MLC, on any company between 1 January 2024 and the earlier of 31 December 2024, or the entry into force of the MLC.

Amount B

  • Amount B of Pillar One provides a framework for the simplified and streamlined application of the arm's length principle to in-country baseline marketing and distribution activities with a particular focus on the needs of low-capacity countries. The Statement says the Inclusive Framework has achieved consensus on many aspects of that framework but, to ensure the appropriateness of all aspects of the Amount B work, the OECD is opening Amount B for further public consultation. The OECD is thus inviting input from stakeholders on the specific elements of Amount B by 1 September 2023 with the work on those elements to be completed by year end.
  • The Inclusive Framework will approve and publish a final Amount B report, content from which will be incorporated into the OECD Transfer Pricing Guidelines by January 2024.


  • The STTR is an integral part of achieving consensus on Pillar Two for developing Inclusive Framework members. Inclusive Framework members that apply nominal corporate income tax rates below 9 percent to intra-group interest, royalties and a defined set of other payments will implement the STTR in their treaties with developing Inclusive Framework members when requested to do so.
  • The Inclusive Framework has completed and delivered an STTR model provision and commentary, a multilateral instrument and explanatory statement. The MLI will amend the treaties that it covers.
  • The MLI will be open for signature from 2 October 2023. Inclusive Framework members can elect to implement the STTR by signing the MLI, or bilaterally amending their treaties to include the STTR when requested by developing Inclusive Framework members.


Contact Information
For additional information concerning this Alert, please contact:
Washington Council Ernst & Young
   •  Any member of the group at (202) 293-7474.


OECD statement on Pillar One

OECD outcome statement