Allocation Keys for Sourcing Revenue under Amount A

Allocation Keys are a key aspect of the Amount A Revenue Sourcing Rules, which attribute revenue to the jurisdictions an MNE group operates in. This is then used when determining how much profit is reallocated to a jurisdiction.

The Allocation Keys effectively simplify the revenue sourcing requirements by basing the sourcing on a high-level formulaic calculation.

There are a number of Allocation Keys including:

• Aggregate Headcount Allocation Key,
• Cargo Air Transport Allocation Key,
• Cargo Non-air Transport Allocation Key,
• Component Allocation Key,
• Global Allocation Key,
• Low-Income Jurisdiction Allocation Key,
• Passenger Air Transport Allocation Key,
• Passenger Non-air Transport Allocation Key,
• Regional Allocation Key, and
• Service Allocation Key.

To see our detailed analysis of Allocation Keys under Amount A, see Amount A – Allocation Keys.