(1) Where the effective tax rate of a jurisdiction in which a constituent entity is located is below the minimum tax rate for a fiscal year, the MNE group or large-scale domestic group shall calculate a top-up tax in accordance with this section separately for each of its constituent entities that has qualifying income included in the calculation of net qualifying income of that jurisdiction for the fiscal year.
(2) The top-up tax percentage for a jurisdiction for a fiscal year, shall be the positive percentage point difference, if any, calculated as follows:
MTR - ETR
where -
MTR is the minimum tax rate, and
ETR is the effective tax rate of the jurisdiction for the fiscal year calculated in accordance with section 111AC.
(3) The jurisdictional top-up tax for a fiscal year shall be the positive amount, if any, calculated as follows:
(TUTP x EP) + ATUJ - D
where -
TUTP is the top-up tax percentage for the jurisdiction for a fiscal year determined in accordance with subsection (2),
EP is
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