Document ID: chunk:federal_register_of_legislation:F2024L01740:front:0:p71
Version: federal_register_of_legislation:F2024L01740
Segment Type: other
Provision Reference: 
Character Range: 178168–180790

Group for the jurisdiction is increased by the absolute value of the sum mentioned in subsection (1).
Note 1: In some circumstances, the balance of the Excess Negative Tax Expense Carry‑forward is applied to reduce the sum of Adjusted Covered Taxes in relation to the jurisdiction mentioned in paragraph 5‑5(2)(a): see subsection 5‑5(4).
Note 2: The balance of the Excess Negative Tax Expense Carry‑forward may also be increased under section 4‑35(3).

5‑15  Meaning of Net GloBE Income and Net GloBE Loss
 (1) If, for an MNE Group for a jurisdiction for a Fiscal Year, the amount computed in accordance with the formula in subsection (2):
 (a) is a positive amount—the Net GloBE Income of the MNE Group for the jurisdiction for the Fiscal Year is that amount; or
 (b) is zero or a negative amount—the Net GloBE Loss of the MNE Group for the jurisdiction for the Fiscal Year is the absolute value of that amount.
 (2) For the purposes of subsection (1), the formula is as follows:
where:
GloBE Income of all Constituent Entities is the sum of the GloBE Income for the Fiscal Year of all Constituent Entities of the MNE Group located in the jurisdiction.
GloBE Losses of all Constituent Entities is the sum of the GloBE Losses for the Fiscal Year of all Constituent Entities of the MNE Group located in the jurisdiction.

Part 5‑2—Top‑up Tax
Note: The Jurisdictional Top‑up Tax or the Top‑up Tax Percentage of an MNE Group for a jurisdiction may be modified by Part 8‑2 (Safe harbours).

5‑20  Meaning of Top‑up Tax Percentage
 (1) Subsection (2) applies in relation to an MNE Group for a jurisdiction for a Fiscal Year if it has an Effective Tax Rate for the jurisdiction for the Fiscal Year.
 (2) The Top‑up Tax Percentage of the MNE Group for the jurisdiction for the Fiscal Year is the amount computed in accordance with the following formula (but not less than zero):
where:
ETR is the Effective Tax Rate of the MNE Group for the jurisdiction for the Fiscal Year.

5‑25  Meaning of Excess Profit
  The Excess Profit of an MNE Group for a jurisdiction for a Fiscal Year is the amount computed in accordance with the following formula (but not less than zero):
where:
Net GloBE Income is the Net GloBE Income of the MNE Group for the jurisdiction for the Fiscal Year.
Substance‑based Income Exclusion Amount is the Substance‑based Income Exclusion Amount of the MNE Group for the jurisdiction for the Fiscal Year.

5‑30  Meaning of Jurisdictional Top‑up Tax
  The Jurisdictional Top‑up Tax of an MNE Group for a jurisdiction for a Fiscal Year is the amount computed in accordance with the following formula (but not less