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