Amount B: The Ghost of Transfer Pricing Simplification Lives

Amount B promised to simplify transfer pricing for routine distribution—a genuine problem consuming six-figure fees on 3% margin transactions. Instead, it haunts the international tax system as a specter of what could have been. The 2025 OECD Model Convention builds elaborate dispute resolution infrastructure for a framework that, per France's July 2025 guidance, "no jurisdiction meets the conditions" to trigger. Developed economies won't implement domestically; covered jurisdictions haven't adopted. Only the US breathed life into it via Notice 2025-4—while simultaneously repudiating the Global Tax Deal. The ghost of transfer pricing simplification lives. It just hasn't found a body yet.