The proposed OECD formulation will mean India getting little revenue despite the large digital and business presence of companies, the official said. This is because only “residual profit” will be apportioned among the countries where a company has its markets. The government is of the view that multinational companies derive large revenues from countries such as India via their digital presence, without having a physical one, and has questioned the distinction between “routine profit”— which accrue due to physical presence — and “residual” profit. “We cannot back this formulation,” the official said. For example, a cab aggregator operating via a mobile app has its core technology base in one country and software base in another but makes money in countries such as India.