Regulation 48

the constituent entities located in the jurisdiction for which the election is made have a deemed distribution tax amount for that financial year, being the lower of —

an amount that, when added to A in section 17(1) for those constituent entities, would result in the effective tax rate (as determined under section 17, including that section as applied by section 22, 23 or 25, or section 24, as the case may be) for those constituent entities for that financial year being 15%; and

the amount of tax that would have been due in that jurisdiction if those constituent entities had distributed all of their profits for that financial year;

the combined adjusted covered taxes of those constituent entities for that financial year are increased by the deemed distribution tax amount; and

a recapture amount equal to that deemed distribution tax amount is recognised for those constituent entities in the next financial year.

first, the amount of any tax paid in that financial year on any actual or deemed distribution of profits by those constituent entities;

then, if those constituent entities have a total negative amount of GloBE income or loss for that financial year, the amount of that total loss (expressed as a positive number) multiplied by 15%; and

then, if any amount computed in sub‑paragraph (b) for those constituent entities for a previous financial year was not fully deducted against the recapture amount of those constituent entities for any previous financial year, the remainder of that amount,on the basis that a recapture amount first recognised in an earlier financial year is reduced before a recapture amount first recognised in a later financial year;

that recapture amount is deducted from the combined adjusted covered taxes of those constituent entities;

then, the effective tax rate (as determined under section 17, including that section as applied by section 22, 23 or 25, or section 24, as the case may be) for those constituent entities is recalculated; and

then, the top-up amounts that those constituent entities would have are recalculated,and section 21(4) (or that section as applied by section 22, 23, 24 or 25, as the case may be) applies accordingly.

leaves the MNE group;

transfers all, or substantially all, of its assets to an entity which is not a constituent entity of the MNE group or to an individual;

transfers all, or substantially all, of its assets to a constituent entity located in another jurisdiction; and

the constituent entities located in that jurisdiction had, in previous financial years, one or more recapture amounts (each called a recapture year),then, for each recapture year —

the recapture amount for that year (after any reduction in paragraph (3)(a)) must be deducted from the combined adjusted covered taxes of those constituent entities for that year;

then, the effective tax rate (as determined under section 17, including that section as applied by section 22, 23 or 25, or section 24, as the case may be) for those constituent entities must be recalculated; and

then, the top-up amounts that those constituent entities would have must be recalculated, and then adjusted by the relevant ratio for each constituent entity,and section 21(4) (or that section as applied by section 22, 23, 24 or 25, as the case may be) applies accordingly.

where the resulting ratio is less than nil, the relevant ratio is nil; and

where the resulting ratio is more than 1, the relevant ratio is 1.