Section 179

Where the jurisdictional Multinational Top-up Tax is attributable to a recalculation under subsection 181(1) and the jurisdiction does not have Net GloBE Income for the current

Financial Year, Multinational Top-up Tax shall be allocated using the formula in section 178 based on the GloBE Income of the Constituent Entities in the Financial Years for which the recalculations under subsection 181(1) were made.