As discussed in Chap. 2 , decentralized platform firms differ from centralized platform firms in several respects, and these differences are salient for tax purposes. Because decentralized platform firms’ network effects are local, regional or national rather than transnational, these firms generally need to develop discrete local, regional or national user bases in each target market jurisdiction. Consequently, they commonly maintain a significant physical presence in each jurisdiction, their management structures tend to be decentralized and their constituent entities may engage in recurrent transactions. For example, they may receive or render intra-group services, license the parent firm’s technology stack (adapted as needed to local market conditions) and use the domain name and other valuable marketing intangible assets developed by the parent firm. They will also generally reproduce the business model and governance systems developed by the parent company. In essence, the foreign subsidiaries of decentralized platform firms replicate the parent company’s platform in toto, and extend its geographic and ecosystem boundaries in the process. Chapter 7 contains a description of a proposed new revenue allocation rule that likens the relationship between decentralized platform firms’ parent companies and their foreign affiliates to that between franchisors and their unaffiliated franchisees, and superimposes the forms of compensation payable by franchisees to their franchisors onto the decentralized platform firm to determine the arm’s length division of revenues among its constituent members for tax purposes. An allocation of group members’ shared costs and expenses is necessary as well to determine the arm’s length division of decentralized platform firms’ pre-tax corporate profits (as distinct from revenues) across taxing jurisdictions.