Executive answer
Amount B is the OECD’s simplified and streamlined approach for certain baseline marketing and distribution activities. It was incorporated into the OECD Guidelines as an annex to Chapter IV and later consolidated with supplementary materials. It defines scope, exclusions, a return-on-sales pricing matrix and application mechanisms.
That does not mean it applies automatically in Mexico. The July 2025 country profile selected “other” and said implementation through secondary regulations remained in process, with details intended for the second half of 2025. A review of available Mexican sources as of August 2, 2026 did not identify a specific published provision establishing domestic application. This is a negative research conclusion, not a guarantee against future publication.
Verification cutoff: August 2, 2026. Before applying the approach, check current Mexican law, annual rules, official gazette, SAT, country profile and OECD updates. This article does not treat the 2025 profile as current implementing law.
What Amount B is
It is a simplification for approximating arm’s-length outcomes for qualifying baseline wholesale distribution transactions. It uses scoping criteria and a matrix based on industry grouping and asset and operating-expense intensities.
It is not a minimum tax, universal margin or global safe harbour for every distributor. Its technical definitions control eligibility.
Origin and evolution
The OECD released the report on February 19, 2024 and incorporated it into the Guidelines. It added tools and materials in December 2024 and later issued a consolidated report.
Record the version and pricing year. Values and tools can change.
Jurisdictional adoption
The approach depends on jurisdiction decisions and relevant commitments. Separate a jurisdiction applying it, a covered jurisdiction committed to respecting results under conditions and one that has not implemented it.
A global policy needs a country-year table, not one universal effective date.
What Mexico’s profile said
In July 2025 Mexico did not select simply yes or no; it selected “other.” It said details were expected in temporary or secondary regulations and implementation remained ongoing. Later questions on implementation form and OES threshold were marked not applicable.
The profile also indicated that Mexico would respect certain outcomes under the political commitment. That does not mean a resident taxpayer may elect domestic application.
What was not found at cutoff
The review of Mexican statutes, the 2026 annual rules and official searches did not identify a specific published provision defining domestic scope, election, mandatory application and procedure.
Because this is a negative conclusion, repeat the search before every use. A later rule can change it.
Request a status and eligibility assessment to separate the OECD method from Mexican application and prepare data without prematurely presenting an outcome as mandatory.
Economic eligibility
Map the distributor, related supplier, products, customers and functions. Identify baseline wholesale marketing and distribution and whether unique contributions, valuable intangibles, significant risks or out-of-scope activities exist.
The label “limited-risk distributor” is insufficient. Compare contracts with conduct.
Transaction delineation
Separate buy-sell distribution from services, commissions, royalties, manufacturing, financing and guarantees. The approach covers qualifying transactions, not the entire entity by default.
If segmented information does not exist, readiness begins with data.
Exclusions
Review excluded products and activities, non-wholesale transactions and other circumstances preventing application. Document each filter and source.
Do not force eligibility to obtain a margin. An exclusion leads back to ordinary analysis.
Pricing matrix
The approach uses return on sales and a matrix organized by industry group and intensity factors. Reproduce classification, net operating assets, operating expenses and sales from controlled data.
Do not copy a percentage from an article. Apply the correct edition and parameters.
Industry grouping
Determine the group for products and activities. Document sources and judgment for mixed portfolios. Classification changes the matrix cell and return.
Trigger review when the mix changes.
Asset intensity
Define net operating assets under the method. Reconcile accounts, averages and exclusions. Do not use total book assets without analysis.
Preserve a trial-balance bridge.
Expense intensity
Classify operating expenses and sales. Review exceptional items, pass-through costs and reclassifications. Accounting differences can move the result.
Document a stable policy and controls.
Segmentation
A distributor may combine wholesale, retail, services and digital channels. Segment revenue, costs, expenses and assets with causal keys.
Segmentation created solely to qualify needs heightened scrutiny.
Additional mechanisms
Review the operating-expense cross-check, data availability mechanism and geographic or jurisdiction adjustments under the relevant version. Do not blend them with an ordinary benchmark.
Every calculation step identifies its source.
Comparison with ordinary TNMM
Calculate Amount B as a scenario and the current method separately. Explain differences in population, indicator, range, years and comparables.
This does not decide which governs in Mexico. It measures exposure and readiness.
Contracts
Review scope, risks, inventory, marketing, warranties, credit, termination and adjustment clauses. Contracts should match conduct.
Do not rewrite functions merely to fit scoping criteria.
Minimum data
Collect sales by product and channel, related purchases, expenses, assets, inventory, receivables, personnel, contracts, organization and decisions. Define a dictionary and owner.
Prepare three years plus a forecast to test stability.
Status tree
First: Did Mexico publish an applicable rule? Second: Which year and taxpayer? Third: Is the transaction eligible? Fourth: Are data reproducible? Fifth: How does the counterparty jurisdiction interact?
If the first answer is no, the calculation remains diagnostic rather than mandatory compliance.
International interaction
The counterparty may be in a jurisdiction applying the approach. Analyze each country’s duties, respect commitment and dispute mechanisms.
Do not presume symmetry. Document the common position and residual risk.
Double taxation
Model differences between Amount B and Mexico’s ordinary method. If an authority adjusts, consider corresponding relief and MAP and preserve deadlines.
The simplification targets certainty, but transition can create scope disputes.
Documentation
Preserve a status memo, eligibility, exclusions, calculation, sources, contracts, FAR, segmentation and comparison. State clearly where it is a scenario.
Do not label it “Amount B applied in Mexico” without published support.
Governance
Global tax monitors OECD developments; Mexico checks the official gazette, SAT and annual rules; accounting prepares data; operations confirms functions; legal reviews contracts. A committee approves the position.
Trigger an alert for new regulation.
Future implementation
If Mexico publishes rules, compare final text with assumptions: election or mandate, years, OES, documentation, adjustments and transition. Update systems before closing.
Do not automatically convert an earlier scenario into a return position.
Warning signs
Warnings include citing only OECD guidance, assuming adoption from a general statutory reference, using an outdated profile, ignoring exclusions, mixing retail, failing to reconcile assets or expenses, treating the matrix as an ordinary range or promising acceptance.
Each warning requires remediation.
Readiness checklist
Confirm country, year, source, status, entity, transaction, wholesale nature, functions, exclusions, industry, sales, assets, expenses, segmentation, matrix, cross-check, contracts, counterparty, documentation and governance.
Mark “pending Mexican rule” where appropriate.
Illustrative example
A Mexican affiliate distributes equipment to third parties and provides support. The group calculates an Amount B scenario, separates support, reviews assets and compares TNMM. Because it does not identify a specific Mexican implementing rule at cutoff, it retains the calculation as readiness and applies a legally supported method.
The foreign affiliate analyzes its jurisdiction separately.
Amount B Readiness product
The deliverable contains a status memo, eligibility tree, FAR, segmentation, calculation, comparison, country-year map, gaps and implementation plan. It does not manufacture regulatory certainty.
The outcome can be ready, ready with gaps, out of scope or pending adoption.
Executive gate
Before any return or policy refers to Amount B, management confirms the Mexican source, year, election or mandatory nature, transaction scope and cross-border effect. If the rule remains unidentified, the document is labeled scenario.
This gate preserves useful preparation while preventing premature compliance claims.
Mexican adoption simulation
Prepare three regulatory scenarios without claiming which will occur. In the first, Mexico permits an election; in the second, it requires the approach for qualifying transactions; in the third, it limits scope or defers entry. For each, identify entities, years, data, systems, returns, contracts and decisions.
Use current OECD parameters only as assumptions. Mark every issue that depends on a Mexican OES threshold, transition, documentation or adjustment process that remains undefined. The company can estimate effort without creating an early tax position.
Mixed-portfolio test
Select products from the main industry groups and review sales, channel, functions, assets and expenses. Identify eligible, excluded and uncertain transactions, then compare segmented outcomes with entity-wide profitability.
One entity can conduct baseline distribution and out-of-scope activities simultaneously. Do not apply the return to the entire income statement. Document segmentation keys and test whether shared assets are assigned causally.
Close-process rehearsal
Run the calculation using one closed year and a forecast. Reproduce the cell, cross-check, adjustments and accounting bridge. Measure preparation time and manual steps. A file understood only by the adviser is not ready.
Configure monthly diagnostic alerts for return, OAS and OES. If a metric crosses a boundary, investigate the business mix and data quality before concluding eligibility changed.
Thirty-, sixty- and ninety-day plan
Within 30 days confirm status and population. By 60 days complete FAR, segmentation and data. By 90 days run scenarios, align the counterparty and document the decision. If Mexico has not issued a rule, retain the package as readiness and schedule review.
Assign an owner in each country. Regulatory monitoring without data preparation still produces a late response when the framework changes.
Questions for a future rule
When one is published, confirm effective date, election or mandate, population, exclusions, OES, matrix years, documentation, adjustments, penalties, transition, open-audit interaction and treatment of foreign outcomes. Compare final text with the 2025 profile.
Do not use historical intent to fill gaps in future wording. Where ambiguity remains, document interpretation and risk.
Evidence of the regulatory search
Retain the Mexican sources reviewed, search terms, date and result. Another reviewer should be able to repeat a negative conclusion; “nothing was found” is not sufficient documentation.
If a secondary publication announces adoption, locate the official instrument before changing policy. Record the discrepancy and schedule follow-up.
Conclusion
Amount B is a concrete OECD methodology, not a generic label. Readiness requires disciplined scope, data and calculation.
For Mexico, the central distinction at August 2, 2026 is between the implementation intention reported in 2025 and an identifiable published provision. Prepare, but do not claim automatic adoption.
Request an Amount B Readiness to verify status, eligibility, data, calculation, international interaction and the update plan.
Verified official sources
- OECD, Consolidated Report on Amount B.
- OECD, transfer pricing and Amount B.
- OECD, Mexico Transfer Pricing Country Profile, July 2025.
- Mexican Chamber of Deputies, current Income Tax Law.
- SAT, 2026 Miscellaneous Tax Resolution.
Verification closed on August 2, 2026. Recheck the identified absence against every later publication.