(1) The effective tax rate of an MNE group or large-scale domestic group shall be calculated for -
(a) each fiscal year, and
(b) each jurisdiction,
provided that there is net qualifying income in the jurisdiction, as calculated in accordance with subsection (3).
(2) For the purpose of this Part, the effective tax rate of an MNE group or large-scale domestic group for a jurisdiction for a fiscal year, shall be calculated as follows:
ACJ / NQI
where -
ACJ is the aggregate adjusted covered taxes of all the constituent entities located in the jurisdiction, and
NQI is the positive amount, if any, of the net qualifying income of all the constituent entities located in the jurisdiction determined in accordance with subsection (3).
(3) The net qualifying income or loss of the constituent entities located in a jurisdiction for a fiscal year shall be calculated as follows:
AQI-AQL
where -
AQI is the positive sum, if any, of the qualifying income of all constituent entities located in the jurisdi
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