Where, pursuant to Articles 15, Paragraph 7 (“disposal of immovable property”), 21, Paragraph 7 (“non-payment of a deferred tax liability”), 24, Paragraph 1 (“adjustment to the covered taxes in the financial accounts”), 24, Paragraph 4 (“non-payment of the amount accrued by a constituent entity as

tax expense and included in adjusted covered taxes for a fiscal year”) and 38, Paragraph 5 (“the deemed distribution tax recapture account”), an adjustment to covered taxes or qualifying income or loss results in the recalculation of the effective tax rate and top-up tax of the MNE group for a prior fiscal year, the effective tax rate and top-up tax shall be recomputed in accordance with the rules set out in Articles 25 to 27. Any amount of incremental top-up tax arising from such recalculation shall be treated as an additional top-up tax for the purpose of Article 25, Paragraph 3 for the fiscal year during which the recalculation is made.

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