Section 177

Notwithstanding subsection (1), for the purposes of

Domestic Top-up Tax, the Jurisdictional Top-up Tax for a jurisdiction for a Financial Year is equal to the positive amount, if any, computed in accordance with the following formula:

(A x B) + C where

A is the Top-up Tax Percentage, being percentage point difference determined in accordance with section 175 for the jurisdiction for the Financial Year;

B is the Excess Profit as determined in accordance with section 176 for the jurisdiction for the Financial Year; and

C is the Additional Current Multinational

Top-up Tax, being the amount determined, or treated as Additional Current Multinational

Top-up Tax, under subsections 169(3) to (4)

or subsection 181(1) for the jurisdiction for the Financial Year.

Multinational Top-up Tax of a Constituent Entity