The Impact of OECD Amount B on Transfer Pricing Compliance in Developing Economies: Cross-Country Evidence and Implications for Uzbekistan

The OECD's Pillar One Amount B (February 2024) introduces a Simplified and Streamlined Approach (SSA) to pricing baseline marketing and distribution activities, targeting low-capacity developing jurisdictions. This paper examines Amount B's impact through a cross-country analysis of 22 developing economies and a focused case study of Uzbekistan. We introduce the "Treaty Coverage Gap" — a novel variable measuring whether an economy's primary FDI source country has committed to Amount B — and find that 45% of the sample faces HIGH or SEVERE gaps that structurally limit the SSA's double taxation relief mechanism. Of these, 80% have China as their primary FDI source. For Uzbekistan — which joined the OECD Inclusive Framework in June 2023, has the newest transfer pricing framework in Central Asia (effective 2022), and derives over 65% of FDI stock from China — we demonstrate that bilateral treaty architecture, not domestic administrative capacity, constitutes the binding constraint on Amount B's effectiveness. We provide five prioritised policy recommendations for Uzbekistan, most urgently bilateral competent authority agreements with China, Russia, and Turkey.