[extraduder_ire]

It's global revenue (all the way up the ownership structure) because that closes one of the world's most obvious loopholes, where you create an EU-based subsidiary that takes a tiny commission for selling products/services from non-EU companies, therefore having minimal revenue to fine. The GDPR fine structure works the same way. Though, 10% is a limit, fines usually start smaller.

If you've read up on BEPS, or most forms of tax-minimization that occur in EU countries, it makes perfect sense that they'd expect that to happen.

[nozzlegear]

That's true, I forgot about the subsidiary sneakiness that corps do all the time. My thought process when asking the question was that yesterday I'd read a discussion here on HN about the US District Court testimony where Tim Sweeny/Epic said that they had deliberately flouted and broken Apple's developer agreement; the argument was that this testimony "doesn't count" because it happened outside of the EU – despite Epic and Epic Sweden being the same business run by the same guy.