We here publish the comments we submitted on the draft model rules on nexus and revenue sourcing, released by the OECD Secretariat for public consultation, in the continuing work to address the tax challenges of the digitalised economy by the Task Force on the Digital Economy (TFDE) set up by the G20/OECD Inclusive Framework on BEPS.

These detailed technical rules for identifying the source of sales would be used in determining which countries would be eligible for an allocation of taxing rights, in respect of around one hundred of the biggest and most profitable multinationals, over so-called Amount A, which is 25% of the ‘residual’ profits, defined as profit in excess of 10% of revenue.