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ARTICLE · 02 MARCH 2021

OECD's Pillar One Blueprint: Revenue Sourcing Rules

Mayer Brown
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The Pillar One revenue sourcing rules determine the revenue that would be treated as deriving from a particular market jurisdiction.

United StatesMedia, Telecoms, IT, Entertainment
Scott Stewart
Scott Stewart
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The Pillar One revenue sourcing rules determine the revenue that would be treated as deriving from a particular market jurisdiction. The rules would be relevant in applying the scope rules, the nexus rules and the Amount A formula. The sourcing rules are reflective of particularities of Automated Digital Services (ADS) and Consumer Facing Businesses (CFB) and more broadly were designed to balance the need for accuracy with the ability of in-scope MNEs to comply, without incurring disproportionate compliance costs. This is proposed to be achieved through the articulation of sourcing principles, supported by a range of specific indicators, subject to a defined hierarchy (likely to be of particular importance in connection with third party distribution). This approach of providing a range of possible indicators within the hierarchy recognizes the different ways MNEs currently collect information in the context of their business model, while still providing certainty to

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