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Pillar One Amount A: Revenue Sourcing Rules

Amount A: Revenue Sourcing Rules

Source of Revenue

Identifying where revenue is sourced from is an essential element of the Amount A calculation, as this is used to determine to which market jurisdictions profits of the multinational group are allocated.

Article 4 and Schedule E of the Progress Report on Amount A of Pillar One provides for detailed revenue sourcing rules. In general, revenues are sourced according to the type of revenue. The draft rules include details of various different types of revenue and where they are deemed to be sourced from. 

If a type of revenue can fall under more than one type of revenue, it is sourced according to its predominant character. 

Revenues are required to be sourced using a reliable method or an allocation key.

General Sourcing Rules

Type of Revenue

Sourcing Rule

Revenues derived from the sale of Finished Goods sold to a Final Customer.

Revenues derived from the sale of Digital Content that are not Components.

Sourced to a jurisdiction where the finished goods are delivered to the final customer.

Where the place of use is.

Revenues derived from the sale of Components 

Sourced to a jurisdiction where the place of delivery to the final consumer of the finished goods that include the component.

Online advertising services .

Sourced to the location of the viewer of the advertisement.

Other advertising.

Sourced to the jurisdiction of the place of display or reception of the advertisement.

Revenues from the provision of Online Intermediation Services that facilitate the sale or purchase of tangible goods, digital content or services.

Sourced half to the location of the purchaser and half to the seller.

Provision of passenger transport services.

Cargo transport services.


Sourced to the jurisdiction of the passenger

The revenue is split half between the jurisdiction of the destination and the other half to the origin jurisdiction.


Customer reward programs.

Sourced to a jurisdiction as a percentage of the active members of the customer reward program located in a jurisdiction. 

Other Services.

Sourced to a jurisdiction  when the place of use of the service is in that jurisdiction.

Intangible property related to finished goods or components.

The place of delivery to the final customer.

Intangible property supporting a service or digital content.

The place of use of content.

Other intangible property

User data

Revenues derived from sale or lease of real property.

The place of use.

Sourced to the location of the user.

Sourced to the location of the real property.


Revenues from government grants.

Other non-customer revenues 


Sourced to the government that made the grant

Sourced as a proportion of the above revenues.


These are the general rules. Schedule E to the Progress Report on Amount A of Pillar One includes a number of reliable indicators that can be used to to determine, for example, the place of use in order that the revenue can then be sourced. 

The Progress Report on Amount A of Pillar One also provides for the use of an allocation key. This can be used:

  • where the group can show it has taken reasonable steps to use a reliable indicator and none is available; and
  • after the application of the Knock-out Rule, which excludes jurisdictions where there is a legal, regulatory or commercial reason so that it can reasonably be concluded that Revenues did not arise in those jurisdictions.

Note that in the case of transport services an allocation key must always be used. 


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