Regulation 43

Where any GloBE income or loss of a permanent establishment is allocated to the main entity of the permanent establishment in regulation 27(2), the qualifying current tax expense in relation to such GloBE income or loss must be allocated to that main entity.

But the amount allocated in accordance with paragraph (1) must not exceed the amount given by multiplying the amount of the GloBE income or loss described in that paragraph by the highest corporate tax rate on ordinary income in the jurisdiction where the main entity is located.

Any deferred tax asset arising under the tax law of the jurisdiction where a permanent establishment is located with respect to a loss that is allocated to the main entity of the permanent establishment in regulation 27(1) must be disregarded in determining the adjusted covered taxes of the permanent establishment.