On 18 February 2022, the public consultation on the draft document on model rules for nexus and revenue under Pillar One closes. The consultation was opened by the Secretariat of the Organisation for Economic Cooperation and Development (OECD) on 4 February 2022. The OECD invited stakeholders to provide input on the methodology and indicators proposed in the revenue sourcing rules. The revenue sourcing rules outlined in the draft document are intended to be used to determine if a specific jurisdiction qualifies for profit reallocation under Amount A of Pillar One. Under the proposed rules, nexus in a specific market jurisdiction would be determined based on a specific type of revenue, e.g. services, intangible property, finished goods, government grants etc. The revenue sourcing rules provide a clear methodology and a set of indicators to be used in the market jurisdiction determination and for jurisdiction approximation for cases in which the necessary information is not available.
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