Turkey has announced that Amount B, a key element of Pillar One in the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project, will not be applied to local transactions involving distributors, sales agents, and brokers. This decision means that, for the time being, there will be no changes to Turkey’s transfer pricing practices in relation to Amount B.
WHAT IS AMOUNT B?
Amount B, developed as part of the OECD’s Two-Pillar Approach, aims to simplify and harmonize transfer pricing rules for routine distribution activities. The initiative primarily focuses on standardizing pricing rules for cross-border transactions conducted by distributors, sales agents, and brokers. It is intended to apply to accounting periods starting on or after January 1, 2025. However, the adoption of Amount B is optional and left to the discretion of each country.
GLOBAL DEVELOPMENTS AND IMPLEMENTATION FLEXIBILITY
As outlined in the OECD’s report published on February 19, 2024, Amount B allows countries to decide whether to apply the framework to transactions within their jurisdictions. A consolidated document providing additional implementation guidance was later released on February 24, 2025, on the OECD’s official website.
TURKEY’S DECISION: NO IMMEDIATE IMPLEMENTATION
Following these global developments, Turkish authorities have evaluated the framework and determined that Amount B will not be applied to transactions involving distributors, sales agents, and brokers operating in Turkey at this stage. This decision preserves the status quo for local transfer pricing regulations.
PUBLIC ANNOUNCEMENT
The public is respectfully informed that there will be no immediate implementation of Amount B in Turkey. Future developments will be closely monitored, and any changes or updates will be announced as necessary.
