Regulation 86

the GloBE income or loss of an NMCE of the MNE group using total revenue as determined in accordance with the relevant CbC Regulations;

the adjusted revenue of such NMCE using total revenue as determined in accordance with the relevant CbC Regulations;

the adjusted covered taxes in the calculation of the effective tax rate for such NMCE using accrued current tax expense as determined in accordance with the relevant CbC Regulations.

the law of the jurisdiction in which the ultimate parent entity of the MNE group is located, implementing the guidance on country‑by‑country reporting contained in the OECD Guidance on Transfer Pricing Documentation and Country‑by‑Country Reporting, published in September 2014 as amended from time to time;

if a country-by-country report is not filed in the jurisdiction mentioned in sub‑paragraph (a) — the law of the jurisdiction in which its surrogate parent entity (as defined in the OECD/G20 Base Erosion and Profit Shifting Project (“BEPS”) Action 13 Final Report published in October 2015) is located that implements the guidance mentioned in that sub‑paragraph; or

if the jurisdiction mentioned in sub-paragraph (a) does not have any law as described in that sub‑paragraph, and the MNE group is not required to file a country‑by‑country report in any jurisdiction — the BEPS Action 13 Final Report published in October 2015, and the OECD Guidance on the Implementation of Country‑by‑Country Reporting published in May 2024.