Amount B in practice: transfer pricing for distributors

TGS Innovised — De Voorwaarts

Updated: 30 September 2026

Amount B simplifies transfer pricing for a foreign sales company, but only in certain countries and for certain activities. On this page, you can read who falls within the scope of Amount B, how the pricing matrix works and what the Dutch position is. This page belongs to the article Transfer pricing for SMEs.

Background to Amount B

Amount B is part of Pillar One of the OECD/G20 Inclusive Framework. In February 2024, the guidance was published as an annex to Chapter IV of the OECD Transfer Pricing Guidelines. Countries may apply Amount B for financial years starting on or after 1 January 2025. The OECD updates the underlying data annually in the Pricing Automation Tool; the 2026 version was published in February 2026.

Amount B is optional. Each country decides for itself whether to apply it. Some countries make Amount B mandatory, others let the taxpayer choose.

Who falls within the scope of Amount B?

Amount B is intended for baseline wholesale distribution of goods:

• Buy-sell distributors that purchase goods from related parties and resell them to independent customers.
• Sales agents and commissionaires that perform sales activities for related parties.

Excluded from Amount B are, among others:

• The distribution of services, commodities and digital goods;
• Distributors with unique and valuable intangibles;
• Distributors that assume economically significant risks that a baseline distributor would not assume;
• Entities that carry out other significant activities alongside distribution, such as manufacturing or R&D.

In addition, there is a quantitative test. Operating expenses must fall within a range relative to sales: between 3% and an upper limit of 20% to 30% chosen by the country.

How does the Amount B pricing matrix work?

The profit margin is expressed as an operating margin on sales (return on sales). It depends on three factors:

1. The industry grouping. There are three groupings, for example food and consumer goods, or machinery and industrial goods.
2. The ratio of operating assets to sales (OAS).
3. The ratio of operating expenses to sales (OES).

The matrix produces a margin roughly between 1.5% and 5.5%, with a narrow range (± 0.5%). In addition, there is an operating expense cross-check, which prevents the outcome from being unreasonably high or low relative to the distributor’s expenses. For certain countries with a higher country risk, an uplift applies.

Illustration (fictitious figures)

Does the actual result differ? Then the transfer price for the purchased goods is adjusted, for example through a year-end adjustment. Always use the current matrix and the percentages of the country concerned.

The Dutch position on Amount B

In the Amount B Decree 2025 (Bedrag B besluit 2025, in Dutch) of 27 November 2024, published on 4 December 2024 and effective from 1 January 2025, the Dutch State Secretary for Finance determined the following:

• The Netherlands does not apply Amount B to Dutch taxpayers. For Dutch distributors, the regular transfer pricing rules continue to apply, with a comparability analysis and benchmark.
• The Netherlands respects Amount B in covered jurisdictions if that country has included Amount B in its legislation for the year concerned, if the Netherlands has a tax treaty with that country and if Amount B has been applied correctly. The Dutch Tax Administration will, in principle, not adjust such a transaction, and the Netherlands will seek to eliminate double taxation, including in a mutual agreement procedure (MAP).

Practical steps

Frequently asked questions about Amount B

More on transfer pricing

Advice on Amount B?

Would you like to know whether Amount B is relevant to your foreign distributor? Contact our international tax specialists.