OECD Pillar One update: What’s next?

Pillar One, Amount A is unlikely to come into force over the next few years. Amount B is not being implemented by many countries and risks being inconsistently implemented by other countries, leaving its future unclear. So why discuss Pillar One in this environment?

The underlying forces that led to Amount A and Amount B (including dissatisfaction with the arm’s length principle, unilateral reactions such as digital services taxes, and transfer pricing controversies around routine activities) remain. To assess where things might be headed, it is important to critically assess the rationale for Pillar One and its current shortcomings.

This month, we will take a deeper dive into some of the technical aspects of Amount A and Amount B, including the link between Amount A and the historical “formulary apportionment versus arm’s length” debate, and the foundations of and potential derivative effects around the Amount B work.

Date: Thursday, April 24, 2025

Time: 1:00–2:15 p.m. ET New York; 10:00–11:15 a.m. PT Los Angeles

Registration: Register for this event.

Panelist

• Bill Morgan, Managing Director, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP. Bill was previously with the US Treasury Department where, among other things, he represented the United States at Working Party 6 of the OECD during the Pillar One work.

Moderator

• Mike McDonald, Managing Director, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP

CPE credit offered: 1.4. Recommended field of study: Taxes. Learning objectives: Discuss the background and the transfer pricing implications of the OECD’s Pillar One, Amount A and Amount B. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax | lynn.fairfax@ey.com and Andrea Ben-Yosef | andrea.ben-yosef@ey.com

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