The international tax system as it currently stands—as yet unmodified by the OECD’s Pillar One—was devised in a specific time and place, when the vast majority of multinational firms had a pipeline structure and existed for the purpose of manufacturing physical products or rendering non-digitalized services. For this reason, the extant profit allocation rules, an integral part of the international tax system, are designed to address the particular fact patterns that are characteristic of multinational pipeline groups. Centralized and decentralized platform firms are an entirely different breed. Their relatively recent emergence necessitates that new profit and revenue allocation rules, respectively, be formulated and implemented for purposes of determining individual jurisdictions’ taxing rights in relation to such firms. In this book, I have proposed a new three-step profit allocation rule applicable specifically to centralized platform firms. The first step entails quantifying and allocating individual centralized platform firms’ net cost savings from barter; the second and third steps correspond to the first and second steps of the U.S. transfer pricing regulations’ Residual Profit Split Method. I have also proposed a new revenue allocation rule applicable specifically to decentralized platform firms. This rule makes use of arm’s length compensation arrangements between franchisors and their independent franchisees to apportion decentralized platform firms’ consolidated revenues between headquarters companies and their foreign affiliates. Under this methodology, the constituent members of such firms would also have to apportion their shared costs and expenses on a reasonable basis. Both nexus and the terms ‘intangible property’ and ‘control’ in the governing regulations would have to be redefined if these proposed profit and revenue allocation rules were to be implemented.