(a) The UTPR top-up tax amount arising pursuant to section 111L(1), 111M(1) or 111AZ(1), as the case may be, of an MNE group allocated to a constituent entity for a fiscal year shall be calculated as follows:
A x B
where -
A is the UTPR top-up tax amount of an MNE group allocated to the State for a fiscal year as determined in accordance with subsection (2), and
B is the UTPR percentage in respect of the constituent entity for a fiscal year as determined in accordance with paragraph (b).
(b) The UTPR percentage in respect of a constituent entity for a fiscal year shall be calculated as follows:
((A / B) x 50 per cent) + ((C / D) x 50 per cent)
where -
A is the total number of employees of the constituent entity,
B is the total number of employees of all the constituent entities of the MNE group located in the State,
C is the sum of the net book values of tangible assets of the constituent entity, and
D is the sum of the net book values of tangible assets of all constituent entities
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