![Amount B](/sites/default/files/styles/ratio_1_1_medium/public/2026-04/iStock-2162033606.jpg.webp?h=08c66182&itok=S8y4ZsY3) [\#Tax & Legal](/en/news?topic%5B777%5D=777) [\#Amount B](/en/news?topic%5B1782%5D=1782) [\#OECD](/en/news?topic%5B327%5D=327) [\#Taxation](/en/news?topic%5B193%5D=193)# Amount B: the OECD takes steps, Belgium proceeds cautiously 30/04/2026 | Reading time: 3 minutes ![Martijn Van den Boer](/sites/default/files/styles/ratio_1_1/public/2023-02/Martijn%20Van%20den%20Boer_Moore_1.jpg?h=036a71b7&itok=1e95IUlE "Martijn Van den Boer") Martijn Van den Boer Senior Manager Tax & Legal Services [Contact](/en/contact) Since the inclusion of Amount B as an annex to the OECD Guidelines in February 2024, both the OECD and national tax administrations have taken further steps in its development and practical implementation. Belgium has also clarified its position through a new circular. While the OECD’s objective is clear, simplifying the pricing of routine marketing and distribution activities, Belgium is adopting a rather cautious approach. For a detailed analysis, we refer to our[ previous publication](https://www.moore.be/en/news/does-amount-b-simplify-the-transfer-pricing-methodology-for-baseline-marketing-and). Below, we briefly revisit the basics of Amount B before taking a closer look at recent developments and the Belgian position. ### What is Amount B? With Amount B, the OECD introduces a **method** to **simplify** and **streamline** the **pricing** of specific **routine marketing** and **distribution transactions** between related parties. To achieve this simplification, the OECD introduces a standardized approach. This standardization operates through a pricing matrix which, based on financial ratios and industry data, determines the return on sales for distributors within its scope. Important: Amount B can only be applied to **qualifying transactions** and is subject to specific **exclusion criteria**. ### What is new? To ensure a consistent application of Amount B, the OECD published in February 2026, among other things: - An updated version of the **Pricing Automation Tool**, including refreshed data such as sovereign credit ratings, supporting the use of the pricing matrix. - A **Frequently Asked Questions** (FAQ) document providing answers to nine technical questions, aimed at ensuring a correct and consistent application. ### What is the Belgian position? Belgium has set out its position on Amount B in Circular 2026/C/45. It clarifies that Amount B is not automatically incorporated into the Belgian transfer pricing framework and that the existing principles from Circular 2020/C/35 remain fully applicable. It is also explicitly emphasized that Amount B should not be considered as a basis for interpreting the general principles set out in the other OECD Transfer Pricing Guidelines, nor as a revision thereof. Belgium is prepared to accept the outcomes of Amount B, but only if the following conditions are cumulatively met: - the counterparty is established in a ‘covered jurisdiction’ (a jurisdiction that politically commits to applying Amount B); - this jurisdiction effectively applies Amount B in line with the OECD Guidelines and has incorporated it into its domestic legislation; - a double tax treaty exists between Belgium and the relevant jurisdiction; - the transactions fall within the scope of Amount B. In addition to the above application conditions, the circular also highlights the following points: - The simplified approach **does not apply** to intragroup transactions that take place entirely within Belgium. - Any subsequent modification (such as an update of the pricing matrix) made to the 2024 report is deemed to be accepted by Belgium. - During a mutual agreement procedure (MAP) or arbitration procedure, an adjustment may be made (subject to certain conditions) to align with the outcome of the simplified and streamlined approach. This is possible where such approach is considered acceptable in the specific case and will be assessed on a case-by-case basis. The above can be applied to both qualifying intragroup transactions and the attribution of profits to permanent establishments, as from **1 January 2025**. If you have any questions regarding Amount B and/or transfer pricing, please do not hesitate to contact us. We would be happy to assist you. Broaden your knowledge about [\#Tax & Legal](/en/news?topic%5B777%5D=777) [\#Amount B](/en/news?topic%5B1782%5D=1782) [\#OECD](/en/news?topic%5B327%5D=327) [\#Taxation](/en/news?topic%5B193%5D=193) Share this news Contact one of our experts [ ![](/sites/default/files/styles/ratio_1_1/public/2023-02/Martijn%20Van%20den%20Boer_Moore_1.jpg?h=036a71b7&itok=1e95IUlE) ### Martijn Van den Boer Senior Manager Tax & Legal Services ](/en/contact) [ ![](/sites/default/files/styles/ratio_1_1/public/2021-11/Joachim%20Janssen_Moore_1_0.jpg?h=ec3b00da&itok=ISJIwPoF) ### Joachim Janssen Partner Tax & Legal Services ](/en/contact) ## Structured data (JSON-LD) ```json { "@context": "https://schema.org", "@graph": [ { "@type": "NewsArticle", "@id": "https://www.moore.be/en/markdownify/node/5552", "name": "Amount B: the OECD takes steps, Belgium proceeds cautiously", "image": { "@type": "ImageObject", "url": "https://www.moore.be/sites/default/files/styles/ratio_1_1/public/2026-04/iStock-2162033606.jpg?h=08c66182&itok=d6QYHgXy" } }, { "@type": "WebPage", "@id": "https://www.moore.be/en/markdownify/node/5552", "breadcrumb": { "@type": "BreadcrumbList", "itemListElement": [ { "@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.moore.be/en" }, { "@type": "ListItem", "position": 2, "name": "News", "item": "https://www.moore.be/en/news" }, { "@type": "ListItem", "position": 3, "name": "Amount B: the OECD takes steps, Belgium proceeds cautiously", "item": "https://www.moore.be/en/markdownify/node/5552" } ] }, "inLanguage": "en" } ] } ```