Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p108
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 270081–272762

Entity's Inclusion Ratio for the Investment Entity; and
 (c) for the purposes of computing that Inclusion Ratio, treat each Investment Entity as a Low‑Taxed Constituent Entity.
Note: That Substance‑based Income Exclusion Amount is relevant to computing the Excess Profit of the MNE Group for the jurisdiction for a Fiscal Year.
 (4) If a Constituent Entity of the MNE Group that is not an Investment Entity has an amount payable for the Fiscal Year in respect of an Investment Entity under a Qualified Domestic Minimum Top‑up Tax of the jurisdiction, treat it as an amount payable by the Investment Entity (see the definition of Domestic Top‑up Tax in section 5‑30).
Note: The amount is also treated as not being an amount payable by the Constituent Entity: see subsection 7‑115(4).
 (5) Treat the Adjusted Covered Taxes of an Investment Entity for the Fiscal Year as being the sum of:
 (a) the Adjusted Covered Taxes for the Fiscal Year of the Investment Entity, to the extent that they are attributable to the MNE Group's Allocable GloBE Income or Loss for the Investment Entity for the Fiscal Year; and
 (b) any Covered Taxes for the Fiscal Year allocated to the Investment Entity under Part 4‑3.
Example: Those Adjusted Covered Taxes can be relevant to computing the following:
(a) the Effective Tax Rate of the MNE Group for the jurisdiction for a Fiscal Year;
(b) any Additional Current Top‑up Tax of the MNE Group for the jurisdiction for a Fiscal Year under sections 4‑30 and 5‑100 (Adjusted Covered Taxes less than expected amount).
 (6) To avoid doubt, the Adjusted Covered Taxes mentioned in subsection (5) do not include any Covered Taxes for the Fiscal Year accrued by the Investment Entity, to the extent that they are attributable to income that is not part of the MNE Group's Allocable Share for the Investment Entity for the Fiscal Year.
 (7) In computing any Additional Current Top‑up Tax of the MNE Group for the jurisdiction for a Fiscal Year under section 5‑100 (Adjusted Covered Taxes less than expected amount), treat the MNE Group's Allocable GloBE Income or Loss for an Investment Entity as the Investment Entity's GloBE Income or Loss.

7‑110  Meaning of Allocable GloBE Income or Loss
 (1) An MNE Group's Allocable GloBE Income or Loss for an Investment Entity for a Fiscal Year is:
 (a) the Investment Entity's GloBE Income or Loss for the Fiscal Year;
multiplied by:
 (b) the Inclusion Ratio of the Ultimate Parent Entity of the MNE Group for the Investment Entity for the Fiscal Year.
Note: In computing that Inclusion Ratio, treat the Investment Entities as the only Constituent Entities of the MNE Group (see section 7‑100).
 (2) For the purposes of