Section 178

Multinational Top-up Tax of a Constituent Entity shall be determined for each Constituent Entity of a jurisdiction that has GloBE Income determined in accordance with Chapter 5

of this Part for the Financial Year included in the computation of Net GloBE Income of that jurisdiction in accordance with the following formula:

A x B

C where

A is the jurisdictional Top-up Tax as determined in accordance with subsection 177(1) or (2), as the case may be, for the jurisdiction for the Financial Year;

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B is the GloBE Income of the Constituent

Entity, being the GloBE Income of the

Constituent Entity determined in accordance with section 165 for the jurisdiction for the Financial Year; and

C is the aggregate GloBE Income of all

Constituent Entities that have GloBE

Income for the Financial Year included in the computation of Net GloBE Income in accordance with subsection 174(4) for the jurisdiction for the Financial Year.