The OECD has released draft model rules for Pillar One of the new global tax rules, specifically the so-called nexus and revenue sourcing for Amount A. The rules are open to public consultation.

The OECD's tax rules say that very large companies will have to pay taxes on 25% of the profit they make above a 10% threshold of revenue (this is called Amount A), and will need to pay it in those countries where they are the most economically active. Countries will therefore have the right to pocket some of the taxes (on Amount A) based on a complex formula for claiming it, and tied to economic activity and the country's own GDP (the nexus rule).

Consultations close on 18 February 2022.

The implementation of Pillar Two is ahead of Pillar One; the OECD released the model rules for Pillar Two in December 2021.

OECD releases Pillar Two Model Rules