111I. Allocation of top-up tax under IIR.

(1) IIR top-up tax due by a parent entity in respect of a low-taxed constituent entity for a fiscal year pursuant to section 111E(1), 111F(1), 111G(1) or 111H(1), as the case may be, shall be equal to an amount calculated as -

A x B

where -

A is the top-up tax of the low-taxed constituent entity, as calculated in accordance with section 111AD, and

B is the parent entity's allocable share in that top-up tax for the fiscal year.

(2)

(a) A parent entity's allocable share in the top-up tax with respect to a low-taxed constituent entity is the proportion of the parent entity's ownership interest in the qualifying income of the low-taxed constituent entity, calculated as -

(A - B) / C

where -

A is the qualifying income of the low-taxed constituent entity for the fiscal year,

B is the amount of qualifying income attributable to ownership interests held by owners other than the parent entity as determined by paragraph (b), and

C is the qualifying income of the low-taxed constituent entity fo

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