Section 174

The Effective Tax Rate of the Multinational Enterprise

Group for a jurisdiction is an amount determined in accordance with the following formula:

A

B where

A is the sum of the Adjusted Covered Taxes of each Constituent Entity located in the jurisdiction for the Financial Year; and

B is the Net GloBE Income of the jurisdiction for the Financial Year.

For the purposes of this Chapter, each Stateless

Constituent Entity shall be treated as a single Constituent

Entity located in a separate jurisdiction.

The Net GloBE Income of a jurisdiction for a Financial

Year is the positive amount, if any, computed in accordance with the following formula:

A – B where

A is the GloBE Income of all Constituent

Entities, being the sum of the GloBE

Income of all Constituent Entities located in the jurisdiction determined in accordance with Chapter 5 of this Part for the

Financial Year; and

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B is the GloBE Losses of all Constituent

Entities, being the sum of the GloBE Losses of all Constituent Entities located in the jurisdiction determined in accordance with

Chapter 5 of this Part for the Financial Year.

The adjusted Covered Taxes and GloBE Income or

Loss of Constituent Entities that are Investment Entities and

Insurance Investment Entities are excluded from the determination of the Effective Tax Rate in subsections (1) to (3)

and the determination of Net GloBE Income in subsection (4).

Multinational Top-up Tax Percentage