INTERNATIONAL TAX PLAZA - Article 28, Paragraph 3

Details: Published: 07 February 2022

Where, pursuant to Article 20(5), additional top-up tax is due, the qualifying income of each constituent entity located in the jurisdiction shall be an amount equal to the top-up tax allocated to such constituent entity divided by the minimum tax rate. The allocation shall be made pro-rata, to each constituent entity, based on the following formula: (Qualifying income or loss x minimum tax rate)-adjusted covered taxes

The additional top-up tax shall only be allocated to constituent entities that record an amount of adjusted covered tax that is less than zero and less than the qualifying income or loss of such constituent entities multiplied by the minimum tax rate.

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