For the reasons discussed in the preceding chapters, a new profit allocation rule applicable to centralized platform firms is clearly called for. In this chapter, I describe one such proposed rule and the conforming changes in the definitions of intangible property, source and nexus that would also be necessary. As a first step, the proposed profit allocation rule allocates centralized platform firms' cost savings from their barter transactions, reduced by their cost of rendering digital services to users, across taxing jurisdictions. These firms' remaining pre-tax operating profits are allocated across jurisdictions in the same two steps provided for in the U.S. Residual Profit Split Method.